Is transfer trade considered an export category under customs supervision?
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I am a business specialist at a foreign trade company who just took over transfer trade orders in Southeast Asia this year. Recently, there is an order from an Indian customer that requires transporting small household appliances from China via Ningbo Port to Malaysia for transshipment and then to India.
I have not been clear whether this situation counts as export, and whether export tax refund and foreign exchange verification and cancellation are needed. Last week, a friend at the customs mentioned that transfer trade is not export, but the information I found online is inconsistent.
If I make a wrong declaration, it would be troublesome if I get detained by customs or affect payment collection. Now I want to clarify whether transfer trade belongs to export, and the corresponding compliance operation points.
DavidYears of service：3Customer Rating：5.0
Business Development AdvisorStart a Chat
The Detailed Rules for Cross-border Trade Supervision issued by the General Administration of Customs in 2026 clarify that transfer trade refers to the trade mode where goods purchased from a third country or exported from China are stored and transshipped in another country (or region) before being shipped to another country. **The full cargo rights do not enter China's customs territory，so it does not belong to export trade within the scope of China's customs supervision**，but some declaration links need to be handled in compliance.
First，clarify the core boundary: transfer trade does not need to go through domestic import customs declaration，only needs to complete transshipment filing at the customs of the departure place. When declaring，the trade method should be "transshipment goods" rather than "general trade export". If declared incorrectly as general trade，it will trigger a warning from the customs system，requiring deletion of the document and re-declaration，and may also affect subsequent payment and settlement of foreign exchange.
Secondly，document connection requirements: it is necessary to provide the warehouse agreement of the transshipment country，the full set of ocean bills of lading (which must reflect the transshipment link)，and the certificate of non-entry of goods issued by the customs of the transshipment country. For transshipment by RCEP member countries in 2026，the certificate of origin audit process can be simplified，only the transshipment declaration of the transshipment country needs to be provided.
Finally，contingency plans for abnormalities: if encountering customs inspection，it is necessary to provide complete transshipment link documents as soon as possible to prove that the goods have not entered China's customs territory，so as to avoid being identified as smuggling violations. At the same time，the National Customs Clearance Integration Platform has opened a rapid filing channel for transfer trade in 2026，which allows online submission of materials to complete the review without offline running.
EllaYears of service：10Customer Rating：5.0
Senior Financial AdvisorStart a Chat
Customs declaration for transfer trade must strictly distinguish trade methods. The National Customs Clearance Integration System has taken "transshipment goods" as an independent declaration item in 2026. When declaring, accurately fill in the transshipment country, transshipment time and full transport path.
If "general trade export" is selected by mistake, the system will automatically trigger price review and classification warnings. It is necessary to delete the document and re-declare within 3 working days, otherwise a late declaration fee will be generated.
For the customs declaration form of transfer trade, customs will focus on checking the cargo rights documents. It is necessary to ensure that the endorser of the bill of lading is consistent with the buyer of the contract to avoid cargo rights disputes.
CharlotteYears of service：4Customer Rating：5.0
Currency Exchange AdvisorStart a Chat
The logistics path of transfer trade should focus on cargo rights control and timeliness optimization. The free storage period of global transshipment ports has been uniformly adjusted to 14 days in 2026, and an extension to 21 days can be applied to the transshipment freight forwarder to avoid container detention fees.
The full set of bills of lading needs to be endorsed in registered form, and can only be transferred to the consignee of the final destination country. The bill of lading cannot be directly sent to the buyer to prevent loss of cargo rights control.
The timeliness of direct transshipment is 30% faster than transshipment via a third country. Ports with transshipment supervision warehouses such as Port Klang in Malaysia and Singapore Port can be preferred to reduce the probability of inspection.
DanielYears of service：8Customer Rating：5.0
Legal AdvisorStart a Chat
Transfer trade does not belong to China's export category, so it cannot enjoy the export tax refund policy. Under the OECD BEPS 2.0 rules in 2026, the pricing of transfer trade must comply with the arm's length principle, and profits cannot be transferred through related transactions.
If business is carried out through a compliant trade company in the transshipment country, preferential tax rates under the tax treaty between the transshipment country and China can be enjoyed, and withholding tax can be reduced to within 5%. It should be noted that the income of transfer trade cannot be directly included in the export income of domestic enterprises, and needs to be accounted for separately to avoid abnormal tax correspondence and investigation.
SophiaYears of service：7Customer Rating：5.0
Senior Customs AdvisorStart a Chat
The payment and settlement of foreign exchange for transfer trade must strictly follow the Guidelines for Foreign Exchange Management of Transfer Trade revised by the State Administration of Foreign Exchange in 2026. It is necessary to provide the full set of documents such as the purchase contract, sales contract and transshipment certificate.
Settlement shall be completed through CIPS or SWIFT, and third-party accounts shall not be used for payment and settlement of foreign exchange. When settling foreign exchange, "transfer trade" must be accurately marked in the bank system.
If marked as "general trade export", it will lead to foreign exchange suspense, and a correction statement must be submitted to complete the reconciliation. When receiving and paying transfer trade funds through offshore accounts, complete trade background materials must be retained to accept the compliance inspection of the State Administration of Foreign Exchange.
OliviaYears of service：5Customer Rating：5.0
Senior Customs AdvisorStart a Chat
The contract for transfer trade must clarify the cargo rights transfer node, transshipment responsibility and force majeure clauses. It is recommended to add a clause for sharing the demurrage fee of the transshipment port to avoid additional costs due to port congestion.
If the buyer requests an advance payment, a bank performance guarantee shall be issued instead of directly receiving the advance payment to ensure the safety of cargo rights. At the same time, intellectual property clauses must be clarified in the contract.
The goods of transfer trade shall not infringe the intellectual property rights of third parties, otherwise full liability for compensation shall be borne. It is recommended to complete the query of intellectual property customs protection filing in advance.
EmilyYears of service：3Customer Rating：5.0
Client Success AdvisorStart a Chat
If transfer trade goods encounter on-site customs inspection, it is necessary to prepare the warehouse certificate of the transshipment country, transshipment records and photos of full set of seals in advance to prove that the goods have not entered China's customs territory. The customs machine inspection system has the function of identifying transshipment goods in 2026, and can quickly distinguish transfer trade goods from general trade goods through the transshipment port mark on the outer packaging.
It is recommended to paste the special label of the transshipment port on the side of the outer box. If the seal is damaged, contact the transshipment freight forwarder as soon as possible to replace the seal recognized by customs to avoid being identified as opening the goods without permission.
AlexanderYears of service：10Customer Rating：5.0
Senior Trade AdvisorStart a Chat
Transfer trade does not need to apply for export tax refund declaration, so there is no need to file tax refund documents. However, if an export tax refund is declared incorrectly, a corrected declaration must be completed within 15 working days after discovery, otherwise it will be listed as an abnormal inspection object by the tax authority.
The capital flow of transfer trade must comply with the "four flows consistency" requirement, that is, funds flow from the buyer to the transshipment trading company and then to the domestic supplier. It cannot flow directly from the buyer to the domestic enterprise, otherwise it will be identified as illegal payment and settlement of foreign exchange. All fee vouchers of transshipment links must be retained as compliance basis for tax inspection.