Is a formal customs declaration form required for transit trade operations in different scenarios?
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I am a small and medium-sized trader engaged in transit trade of electronic components in Southeast Asia. Recently, I received an order to ship goods from Vietnam to Thailand via the Shanghai Bonded Zone. Previously, a familiar colleague told me that no customs declaration form is needed for pure transit business. However, when I went to the bank for cross-border payment and settlement last week, the account manager reminded me that it is better to attach customs declaration documents if available, otherwise it will most likely trigger anti-money laundering risk control alerts. I am completely confused now.
The vessel will arrive in 3 days, and if the cargo is detained due to lack of compliant documents, everything will be ruined. My working capital is already tight, and I can't afford large container detention fees or port detention fees. Do I need a customs declaration form for transit trade? Are the requirements different for different operation scenarios? Is there a clear compliance standard for reference?
OliviaYears of service：5Customer Rating：5.0
Senior Customs AdvisorStart a Chat
Many practitioners have a misunderstanding that transit trade，as a business with both ends outside China，does not require a customs declaration form at all. In fact，the rules are determined based on whether the goods enter China's customs territory，and there is no unified "yes" or "no" conclusion.
If the entire batch of goods does not enter China's customs territory at all and completes transshipment directly at an overseas port，there is no need to make any declaration to the Chinese customs，so naturally no customs declaration form is required. If the goods need to enter China's bonded supervision areas for transit storage，container replacement and sorting，you need to submit the Transit Goods Inbound and Outbound Record List to the customs. This record list is completely equivalent to a customs declaration form in terms of regulatory effectiveness and is a compliant official declaration document.
Your current business belongs to transit trade via bonded zone. During the pre-document review stage，you should prepare the tripartite purchase and sale contract，full journey ocean bill of lading，and cargo title transfer endorsement documents in advance. The commodity name，quantity，and consignor/consignee information in all documents must be completely consistent. You need to complete the inbound record declaration for transit goods 24 hours before entering the bonded zone. When the goods are sorted，re-packed and ready for departure，submit the outbound record declaration simultaneously. The declaration data at the two nodes must correspond one-to-one without logical discrepancies.
If the goods are about to arrive at the port and you haven't completed the pre-declaration，you can directly use the fast pre-entry channel for transit goods on the Single Window，instead of going through the general import and export customs declaration process. The record pre-review can be completed within 1 hour. When handling cross-border payment and settlement later，you can directly submit the transit record list to replace the general import and export customs declaration form，which fully complies with the 2026 national unified foreign exchange regulatory requirements and will not trigger any risk control alerts.
DavidYears of service：3Customer Rating：5.0
Business Development AdvisorStart a Chat
The data of the inbound and outbound record list for transit goods will be directly synchronized to the shared database of the customs and the foreign exchange administration, and has the same legal effect as general import and export customs declaration forms, so there will be no data disconnection. When declaring, note that the supervision code for transit goods should be filled as "5134", and do not mistakenly fill in the code for general trade or bonded storage, otherwise it will lead to failure in subsequent foreign exchange verification.
If you have made a wrong declaration before, you can directly submit an amendment application on the Single Window. As long as you can provide complete tripartite trade documents, the data can be corrected within 3 working days without any violation records. Do not believe the so-called "no declaration needed for transit trade" statement. Once there is no corresponding record data of the goods in the bonded zone system, the goods will be directly detained by the port area upon arrival. Later, you need to submit a large number of explanatory materials to complete the port clearance, and the additional cost will be at least 3 times that of normal declaration.
EmilyYears of service：3Customer Rating：5.0
Client Success AdvisorStart a Chat
When choosing transit routes, you can prioritize shipping companies that support "direct transit". Such shipping companies can directly input transit manifest data in advance at the port of origin. After the goods arrive at the port, they can complete transshipment directly without unloading, and do not need to enter the port yard throughout the process.
The free storage period can be up to 14 days, and no port detention fees will be incurred. The consignor column on the bill of lading should indicate the actual cargo title holder, and do not use the freight forwarder's name as the consignor, otherwise there will be operational obstacles when endorsing the cargo title transfer later. If you need to change the transit port or final destination later, you can submit a modification application to the shipping company 48 hours before the goods arrive at the transit port, and the amendment can be done for free without additional amendment fees.
CharlotteYears of service：4Customer Rating：5.0
Currency Exchange AdvisorStart a Chat
The profits from transit trade can be directly retained in offshore accounts and do not need to be included in the VAT taxable income of domestic enterprises. As long as you can provide complete transit record documents, cargo title transfer documents and full journey transportation documents, you do not need to pay domestic VAT, and only need to declare non-trade operating income in accordance with regulations to pay corporate income tax.
Do not confuse the payment and settlement of transit trade with the capital flow of general import and export trade, and do not use domestic VAT special invoices to match the costs of transit business, otherwise it will trigger risk alerts for cross-border related transaction pricing. If the annual revenue from transit trade accounts for more than 60% of the total revenue, you can apply for tax compliance certification for cross-border trade structures, and the priority of subsequent BEPS screening will be significantly reduced.
WilliamYears of service：10Customer Rating：5.0
International Logistics AdvisorStart a Chat
When handling cross-border payment and settlement for transit trade, the CIPS system will automatically match the transit record list data you submit. As long as the document information is completely consistent with the payer and payee information in the capital flow, the funds can be received in seconds without manual verification. For each cross-border payment and settlement of transit trade in the offshore account, you need to retain the corresponding document copies for a period of no less than 5 years.
When encountering SWIFT message verification spot checks, you can directly upload the record list to replace the customs declaration form without preparing additional explanatory materials. Do not split and transfer the funds of transit trade through third-party accounts, otherwise it will directly trigger high-frequency transaction risk control alerts and lead to temporary account freezing.
DanielYears of service：8Customer Rating：5.0
Legal AdvisorStart a Chat
When signing the tripartite contract for transit trade, clearly specify the specific location of the transit port, the node of cargo title transfer, and the corresponding document submission obligations of each party in the contract clauses to avoid subsequent disputes over cargo title ownership.
If letter of credit settlement is involved, clearly stipulate that the transit record list can be submitted as the cargo title document under the letter of credit, and do not add soft clauses requiring the submission of the import customs declaration form of the destination country, otherwise there will be problems of document discrepancies and inability to honor the payment. If the goods are damaged during transit, the corresponding cargo damage claim process can be directly submitted to the insurance company based on the transit record list without providing additional import and export customs declaration forms.
RobertYears of service：6Customer Rating：5.0
Warehouse Management AdvisorStart a Chat
The inspection priority of transit goods after entering the bonded zone is much lower than that of general import and export goods. As long as you upload complete manifest data and cargo details in the system in advance, more than 95% of transit goods can directly go through the machine inspection channel for quick release without manual unpacking inspection.
When receiving on-site inspection notice, directly submit the relevant contracts and record instructions for transit trade to the on-site customs officers, and cooperate with the seal number verification to complete the inspection quickly without additional inspection fees. If the on-site customs officers require sending some goods for component identification, you can mostly exempt the inspection process by submitting the pre-prepared MSDS report, saving at least 3 days of waiting time.
EllaYears of service：10Customer Rating：5.0
Senior Financial AdvisorStart a Chat
No import and export customs declaration form is required for document filing of transit trade. As long as you organize and file the tripartite purchase and sale contract, full journey bill of lading, transit record list, and payment and settlement documents to ensure that the four flows (goods flow, document flow, capital flow, and transaction flow) are completely matched, you can directly submit them for verification when encountering tax audits, which fully complies with the document management requirements related to export tax refund.
The foreign exchange received from transit trade does not need to participate in the foreign exchange verification for export tax refund, and will not affect your normal export tax refund progress for general trade. If you have mistakenly declared transit business into general trade export data before, you can submit a statement for data adjustment during the export tax refund settlement period of the next year without generating violation records.