Do Transshipment Trade Enterprises Have to Complete Customs Declaration? 2026 New Regulation Interpretation
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I am the person in charge of an enterprise specializing in transshipment of electronic products between Southeast Asia and Europe. Recently, a batch of chips imported from Malaysia needs to be transshipped via Singapore before being exported to the Netherlands, with the whole customs declaration process handled at Shanghai Port.
Due to frequent updates of customs policies in 2026, we are worried about non-compliance in customs declaration leading to cargo port detention. We are not clear whether we need to fill in complete transshipment information in the declaration at Shanghai, and we heard that the new valuation rule may require the provision of value-added certificates for the transshipment country.
In addition, the logistics involves endorsement of multi-leg bills of lading, what should be noted if the ownership of the goods changes in the intermediate links? We hope to clarify the core customs declaration process, application of special policies and key points for risk avoidance, so as to avoid additional costs caused by operational errors.
SophiaYears of service：7Customer Rating：5.0
Senior Customs AdvisorStart a Chat
Enterprises engaged in transshipment trade must complete customs declaration in accordance with the law. In 2026，Shanghai Port has established an operational framework of "whole-chain compliance + regional linkage" for transshipment business. The core operation needs to complete four-step closed-loop management:
I. Details of Pre-document Review: Focus on verifying the through bill of lading (marked with Singapore transshipment port code and transshipment cost allocation certificate)，certificate of origin (FORM E must clearly indicate Malaysia as the country of origin)，and transshipment trade filing form (newly added transshipment country value-added rate calculation sheet). The "International Transit Goods Origin Declaration Specification" newly introduced in 2026 requires additional provision of value-added processing certificate for goods in the transshipment country (which can be exempted for non-substantial processing).
II. Key Points for Core Node Connection: Complete three-level traceability information of "country of origin / transshipment country / final destination" in the declaration elements，prepare the market value comparison report of goods in the transshipment country (such as Singapore port inquiry records) during the valuation process，apply for bonded warehouse inspection in advance for inspection (the "Transit Goods Supervision Commitment Letter" is required).
III. Exception Response Plan Design: If there is an error in the declaration elements，it can be handled through the dual-track process of "pre-declaration verification - on-site document modification" to avoid delay caused by deleting and re-submitting the declaration，in case of missing documents，the goods can be picked up first and the documents supplemented later with the Temporary Customs Clearance Certificate issued by E-Port.
IV. Compliance Implementation Guarantee: Priority is given to the green channel for AEO certified enterprises，and transshipment goods can apply for the "release first，verification later" mode. It is recommended to note "Transshipment Trade (transshipment costs listed separately)" in the remarks column of the customs declaration form to reduce the probability of customs classification disputes.
OliviaYears of service：5Customer Rating：5.0
Senior Customs AdvisorStart a Chat
Chief Customs Declaration Specialist: It is necessary to focus on the "transshipment country operation description" in the declaration elements. In 2026, the customs added a new requirement that "the transshipment port must have an actual stay duration of no less than 72 hours to apply for transshipment trade policies".
It is recommended to prepare the Cargo Storage Certificate issued by the Maritime and Port Authority of Singapore to avoid being judged as "fake transshipment" due to insufficient transshipment time.<。
WilliamYears of service：10Customer Rating：5.0
International Logistics AdvisorStart a Chat
>Senior Logistics Specialist: Multi-leg bill of lading shall adopt the dual insurance of "segmented endorsement + goods ownership transfer declaration". When transshipping in Singapore, the bill of lading shall be marked "only serving as a transport tool, and the goods ownership is transferred along with the master bill of lading".
It is recommended to use SWOP (Segmented Combined Transport Bill of Lading) to avoid disputes over goods ownership under multi-modal transport bill of lading.<。
CharlotteYears of service：4Customer Rating：5.0
Currency Exchange AdvisorStart a Chat
>Senior Tax Consultant: A new VAT deferral pilot is launched in 2026. Qualified transshipment enterprises can apply to pay the import value-added tax after the final sales are completed in the Netherlands.
It is necessary to prepare the value-added rate calculation of goods in the transshipment country in advance (for example, the import price from Malaysia is 1 million, and the value added in Singapore transshipment is 10%) as the basis for the deferral application.<。
DavidYears of service：3Customer Rating：5.0
Business Development AdvisorStart a Chat
>Trade Compliance Specialist: Foreign exchange collection must match the amount on the customs declaration form. It is recommended to give priority to completing cross-border payment via the CIPS system to avoid foreign exchange suspense caused by delayed SWIFT messages.
If the designated account of the Dutch importer is involved, mark "Special Account for Euro Settlement" in the remarks column of the customs declaration form.<。
AlexanderYears of service：10Customer Rating：5.0
Senior Trade AdvisorStart a Chat
>Foreign Trade Legal Specialist: Bill of lading endorsement must strictly follow the combined principle of "blank endorsement + special endorsement". The Malaysian exporter shall affix the seal of "negotiable only to the consignee in the Netherlands" on the back of the original bill of lading, to prevent illegal transfer of goods ownership by third parties in transit.<。
DanielYears of service：8Customer Rating：5.0
Legal AdvisorStart a Chat
>On-site Inspection Specialist: Pre-submit the Inspection Pre-application 48 hours in advance for transit goods inspection, and mark "No Wooden Packaging in Bonded Warehouse". If abnormality is found in the machine inspection, apply for "unaccompanied inspection" for fast release, so as to avoid over-storage fees incurred by port detention.<。
EmilyYears of service：3Customer Rating：5.0
Client Success AdvisorStart a Chat
>Special Packaging Engineer: The anti-static packaging of electronic components for transshipment must comply with UN 3480 standards. For sea transport, additional "Moisture Proof + Vibration Proof" labels shall be affixed.
It is recommended to note "No Stacking and Heavy Pressure Allowed During Transshipment" in the packing list in advance to reduce the risk of packaging disputes during inspection.<。
JohnYears of service：6Customer Rating：5.0
Export Tax Rebate AdvisorStart a Chat
>Export Tax Rebate Auditor: Foreign exchange verification and cancellation must strictly match the amount on the customs declaration form. If the difference is no more than 5%, it can be exempted through "difference statement".
The "Special Transshipment Trade Tax Rebate Filing Form" newly added in 2026 needs to be attached with the value-added invoice from the transshipment country as the tax calculation basis.。