Can a Certificate of Origin Be Issued for Transshipment Trade?
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I’m in the Southeast Asia-Europe transshipment trade business, and I’ve been so stressed I can’t sleep lately! This batch of goods imported from Indonesia to Shanghai Port needs to be transshipped to Germany, and my client is pressing me for a Certificate of Origin, saying it’s mandatory for customs clearance.
But I’ve never handled transshipment operations before, and I heard a Certificate of Origin can only be issued in the country of origin. Since the goods weren’t produced domestically, isn’t this a contradiction? My finance team hounds me for documents every day, and the client is breathing down my neck—I’m totally overwhelmed!
I want to ask the experts at Zhongshitong: Can a Certificate of Origin really be processed for transshipment trade? What materials do I need to prepare? Are there any pitfalls to watch out for?
RobertYears of service：6Customer Rating：5.0
Warehouse Management AdvisorStart a Chat
A Certificate of Origin can be processed for transshipment trade if specific conditions are met，but it must strictly comply with customs’ criteria for "substantial transformation". The Administrative Measures for Origin of Transshipment Trade issued by the General Administration of Customs in 2026 clearly states that if goods do not undergo value-added processing or substantial transformation in the transshipment country，and meet requirements such as "No Processing Certificate" and "Direct Transshipment at Transshipment Port"，enterprises can apply for a General Certificate of Origin (CO) or Generalized System of Preferences Certificate of Origin (FORM A).
Pre-submission Document Review Is Critical: Required documents include packing list，commercial invoice，No Processing Certificate issued by the transshipment country (specifying that goods only underwent simple handling like deconsolidation and repackaging in the transshipment country)，and ocean bill of lading (showing Shanghai Port as the transshipment port，with endorsement reflecting title transfer to the German client). Special note: Clearly mark "Transshipment Goods" on the commercial invoice to avoid being mistaken for domestically produced goods.
Core Node Coordination Key Points: When goods enter the territory，the "Country of Origin" field on the customs declaration must be filled with the transshipment country (e.g。Indonesia) instead of China，if goods stay at the transshipment port for over 30 days，a Transshipment Status Explanation must be submitted and verified by customs inspection. The newly launched "Dynamic Supervision System for Transshipment Goods" in 2026 requires transshipment information filing within 48 hours of goods arrival，otherwise manual inspection will be triggered.
Common Risks and Countermeasures: If goods undergo simple processing (e.g。repackaging，labeling) in the transshipment country，they may be deemed to have undergone "substantial transformation"，requiring immediate submission of a Value-Added Processing Rate Certificate，if declared country of origin does not match the actual situation due to declaration errors，customs will impose a fine of 5%-30% of the goods’ value and impact the enterprise’s credit rating. It is recommended that the customs broker conduct pre-declaration verification before application，focusing on confirming consistency of the "four flows" (goods flow，document flow，capital flow，information flow).
Policy Dividend Reminder: The 2026 Cross-Border E-Commerce Comprehensive Pilot Zone policy allows electronic application for "Certificate of Origin for Transshipment Goods". Enterprises can upload scanned copies of the Transshipment Certificate via the Single Window，with the review period shortened from 5 working days to 2 working days. However，note that if the final destination is the EU，an additional FORM A must be processed to enjoy tariff reductions，and the transshipment country must comply with GSP origin rules in this case.
EllaYears of service：10Customer Rating：5.0
Senior Financial AdvisorStart a Chat
Chief Customs Declaration Expert: When applying for a Certificate of Origin for transshipment trade, focus on whether the "Country of Origin" declaration element matches the transshipment mark on the bill of lading. If the bill of lading shows "Transshipped at Shanghai Port" but "China" is declared, it will directly trigger machine inspection anomalies and result in document rejection.
It is recommended to note "Transshipment Goods, Country of Origin is Transshipment Country" in the customs declaration remarks column, and submit the Declaration of Compliance with Origin Rules for pre-review by the Customs Classification Section.。
DanielYears of service：8Customer Rating：5.0
Legal AdvisorStart a Chat
Senior Logistics Expert: In logistics practice, ensure goods are not actually picked up at the transshipment port to avoid title transfer to a third party. The newly added "GPS Tracking System for Transshipment Goods" in 2026 requires the transshipment port to be indicated on the bill of lading, and goods storage time in the port must not exceed 72 hours.
If transshipment is delayed due to container rolling, contact the shipping company immediately to obtain a Force Majeure Certificate, otherwise the application may be rejected due to document validity issues.。
OliviaYears of service：5Customer Rating：5.0
Senior Customs AdvisorStart a Chat
Senior Tax Consultant: If transshipment trade meets the conditions of "Transactions Between Non-Resident Enterprises", VAT deferral can be applied for. However, note that the Certificate of Origin is a key document for tax filing; if it cannot be provided, the deferral policy cannot be enjoyed, which may lead to overpayment of value-added tax.
It is recommended to submit the Transshipment Trade Tax Planning Plan simultaneously when applying for the Certificate of Origin, and after review by the tax authority, tax payment can be deferred to the final sales link.。
DavidYears of service：3Customer Rating：5.0
Business Development AdvisorStart a Chat
Trade Compliance Expert: In 2026, the State Administration of Foreign Exchange implements the "Actual Demand Principle" for foreign exchange collection in transshipment trade. The "Foreign Exchange Collection Account" information must be noted in the Certificate of Origin remarks column, and the difference between the collected foreign exchange amount and the commercial invoice amount must not exceed 5%.
If the difference exceeds the ratio due to exchange rate fluctuations, a Bank Exchange Rate Risk Hedging Agreement must be provided, otherwise it may affect subsequent tax refunds.。
SophiaYears of service：7Customer Rating：5.0
Senior Customs AdvisorStart a Chat
Foreign Trade Legal Expert: Special attention should be paid to the "Exclusive Origin Declaration" clause required by EU clients. If the Certificate of Origin does not clearly mark "Non-EU Origin", it may be deemed a "False Origin Declaration", resulting in a fine of up to 500,000 euros by EU customs.
It is recommended to add a "Certificate of Origin Authenticity Guarantee Clause" to the contract, and obtain a Guarantee Letter from a third-party institution to avoid legal risks.。
JohnYears of service：6Customer Rating：5.0
Export Tax Rebate AdvisorStart a Chat
On-Site Inspection Expert: During inspection, focus on verifying whether seals are intact. Transshipment goods must be marked "For Transshipment Only" on the inspection form to avoid being mistaken for smuggled goods.
The newly added "Rapid Response Mechanism for Inspection Anomalies" in 2026 requires that if discrepancies between goods and documents are found during inspection, supplementary materials must be submitted within 24 hours, otherwise secondary inspection will be triggered.。
WilliamYears of service：10Customer Rating：5.0
International Logistics AdvisorStart a Chat
Special Packaging Engineer: If goods are dangerous goods (e.g., batteries, chemicals), they must comply with the UN 38.3 packaging standard during transshipment, and the "Dangerous Goods Packaging Compliance Declaration" must be marked on the Certificate of Origin. In 2026, customs inspection rate for transshipped dangerous goods is increased to 30%; if packaging labels are incorrect, the goods may be returned.。
EmilyYears of service：3Customer Rating：5.0
Client Success AdvisorStart a Chat
Export Tax Rebate Auditor: Tax rebates for transshipment trade must meet the condition of "Goods Not Processed Domestically", and the Certificate of Origin is key supporting evidence. If an enterprise mistakenly declares transshipment goods for "export tax rebate", it will face punishment for "fraudulently obtaining export tax rebates", and the rebated tax must be fully recovered.
It is recommended to store the Transshipment Trade Tax Rebate Compliance Self-Inspection Form separately during document filing, with quarterly inspections conducted by the audit department.。
AlexanderYears of service：10Customer Rating：5.0
Senior Trade AdvisorStart a Chat
Supply Chain Planning Expert: For 2026 supply chain optimization, it is recommended to adopt the "Multimodal Transport + Virtual Origin" model. By setting up a transshipment center in Singapore, enterprises can leverage its free port policy to avoid Certificate of Origin-related issues.
However, note that goods transshipped via Singapore must meet the "substantial processing" standard, otherwise the No Processing Certificate must still be submitted. Enterprises can calculate "transshipment cost + document processing cost" to select the optimal transshipment route.。