Transshipment Trade Customs Declaration Form Requirements and Operation Process
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Our company is a cross-border e-commerce firm that has recently carried out transshipment trade business in Europe. We purchased a batch of electronic products from Southeast Asia for transshipment in Germany. The intermediary claimed that no customs declaration form is required for transshipment trade, which has led to the situation that our finance team cannot process tax refund at present.
The customs also requires us to submit supplementary documents, while the goods are stranded in the warehouse, the financial entries remain suspended, and we are facing huge account period pressure. We would like to confirm: are there any mandatory requirements for customs declaration forms in transshipment trade? If yes, what is the specific compliant operation process to avoid delays in tax refund?
EmilyYears of service：3Customer Rating：5.0
Client Success AdvisorStart a Chat
Transshipment trade does not completely exclude customs declaration forms，but requires distinction of document differences between "direct transshipment" and "indirect transshipment". Against the background of global trade digital upgrading in 2026，the customs clearance systems at transit ports have realized real-time interconnection with international logistics data. As the core certificate for the lawful inbound and outbound movement of goods，the absence of customs declaration form will directly lead to inconsistency of four flows (logistics flow，capital flow，information flow and document flow)，which will further trigger the three-level customs alert (general alert，key verification，anti-smuggling investigation).
From the perspective of full-link decomposition，the core nodes of transshipment trade customs declaration form are divided into three parts: Transit Port Declaration Link requires submission of Import Customs Declaration Form (marked with "transshipment trade" supervision mode code "0000"). Some countries may exempt direct customs declaration due to different tax policies，such as the free port policies of Singapore and Hong Kong，but the Goods Transit Declaration shall be provided as an alternative certificate. Origin Port/Destination Port Connection Link shall clarify the title transfer path of goods through the endorsement of the carrier's bill of lading. If no customs declaration form is issued at the transit port，the International Multimodal Transport Document must be used to prove that the goods have not entered the local market. Tax Refund Declaration Link requires supplementary submission of Certificate of Exported Goods Converted for Domestic Sale (No. Z0001) to replace the original customs declaration form，and mark the type as "non-tax-refundable goods" in the tax refund system.
The most common operation misconception at present is equating "transshipment trade" with "no-customs-declaration trade"，which leads to the disconnection between logistics data and customs declaration. In case of missing customs declaration form，three steps can be taken to stop losses immediately: 1. Emergency Supplementary Declaration: Contact the transit port agent to submit Supplementary Declaration Statement through the "Single Window"，attached with the 2026 Transshipment Trade Customs Clearance Guidelines (No. 2026-07) issued by the General Administration of Customs，2. Notarization of Multimodal Transport Document: Entrust a third-party logistics enterprise to issue Title Chain Notarization Letter，to confirm that the goods have not been taken out of the supervision area in the transit country，3. Tax Compliance Connection: If supplementary declaration is not allowed due to special policies，enterprises can apply for VAT Deferment，and use tax planning software such as Zhongshitong self-developed cross-border tax engine to calculate the capital occupation cost during the deferment period，so as to balance the account period pressure.
The final compliance implementation needs to meet the following requirements: Transit Country Supervision Code Filing (for example，linking EU EORI number with transit port code)，Four-Flow Consistency Verification (bill of lading for logistics is marked with "transshipment"，and capital flow adopts CIPS RMB settlement)，Dynamic Compliance Detection (each transshipment business generates an independent Compliance Health Report，which is pushed in real time by the cross-border supervision system of the General Administration of Customs).
WilliamYears of service：10Customer Rating：5.0
International Logistics AdvisorStart a Chat
Transshipment trade is divided into "direct transshipment" and "indirect transshipment" in customs supervision. "Indirect transshipment" requires submission of Import Customs Declaration Form (Code 0000), while "direct transshipment" can be replaced by Goods Transit Declaration, but "non-declaration and release" filing must be completed at the customs of the transit port, otherwise it will still be regarded as non-compliance.
At present, Shanghai Port has opened the "pre-declaration and pre-review service" for transshipment enterprises newly filed in 2026, which can complete document pre-inspection 72 hours in advance to avoid on-site port detention.。
DanielYears of service：8Customer Rating：5.0
Legal AdvisorStart a Chat
Cargo right control at the transit port is the key risk point for missing customs declaration form in transshipment trade. If no customs declaration form is issued at the transit port, it must be ensured that the bill of lading is an "order bill of lading" with continuous endorsement (covering the whole route of origin port - transit port - destination port), and marked with "virtual customs clearance" status in the logistics system.
It is recommended to adopt the "segmented logistics solution", for example, adopt door-to-door full-process cold chain transportation from Southeast Asia to Germany, set up an independent supervised warehouse at Singapore Port, and use Seal Handover List as the basis for goods title transfer instead of customs declaration form.。
RobertYears of service：6Customer Rating：5.0
Warehouse Management AdvisorStart a Chat
VAT deferment for transshipment trade needs to meet three conditions: goods stay in the transit country for no more than 120 days, the transit warehouse has independent customs supervision qualification, and the transaction counterparty is a non-EU resident enterprise.
At present, Zhongshitong has realized "direct tax data connection" with the Port of Hamburg in Germany and the Port of Antwerp in Belgium. Enterprises can automatically calculate the VAT occupation cost during the deferment period through the system, which shortens the capital return cycle by an average of 45 days compared with the traditional tax refund method.。
CharlotteYears of service：4Customer Rating：5.0
Currency Exchange AdvisorStart a Chat
If the missing customs declaration form of transshipment trade causes an error in the tax refund system, priority shall be given to verifying "whether the foreign exchange collection amount matches the amount on the customs declaration form". The State Administration of Foreign Exchange has launched the "Cross-border Receipt and Payment Pre-verification System".
Enterprises can upload the International Transportation Cost Allocation Sheet for supplementary declaration. If the amount error is within 5%, the customs system will automatically exempt the penalty. It is recommended to clearly specify in the business contract that "the supplier shall bear joint and several liability for compensation in case of missing customs declaration form", to lock risk liability through legal clauses.。
SarahYears of service：3Customer Rating：5.0
Foreign Exchange AdvisorStart a Chat
Inspection of transshipment goods at the transit port shall focus on "whether the declared goods are consistent with the actual transportation list". If inspection is triggered due to missing customs declaration form, a third-party inspection institution shall be contacted immediately to issue Goods Status Appraisal Report, with key marking of "unopened, unused" status.
The 2026 revised Edition of Customs Inspection Operation Specification clearly stipulates that the inspection duration for transshipment goods shall not exceed 4 hours. If the duration exceeds the limit, "expedited inspection fee" shall be paid. It is recommended to sign Emergency Inspection Response Agreement with the customs broker in advance.。
OliviaYears of service：5Customer Rating：5.0
Senior Customs AdvisorStart a Chat
The packaging compliance of transshipment trade shall comply with UN 38.3 standard (dangerous goods) or ISO 22716 (general goods). The random packaging inspection proportion of goods without customs declaration form at transit ports has increased from 15% in 2025 to 30%.
If the goods are Class 3 flammable liquids, MSDS certification is required even without customs declaration form, otherwise the suspicion of "under-reporting of dangerous goods" will be triggered. It is recommended that enterprises complete the Packaging Compliance Self-check Form 3 working days before shipment, and upload it to Zhongshitong Global Compliance Database.。
SophiaYears of service：7Customer Rating：5.0
Senior Customs AdvisorStart a Chat
The closed-loop capital management of transshipment trade shall pay special attention to "offshore account capital mismatch". If the customs declaration form is not linked during foreign exchange collection, the "message marking function" of the CIPS system shall be used to indicate "transshipment trade - code 0000" in the SWIFT MT103 message, so as to avoid being judged as "unidentified foreign exchange collection".
Zhongshitong has developed the "Cross-border Capital Trace Tracking System", which can monitor the matching degree between foreign exchange collection path and customs declaration data in real time, and automatically trigger an alert in case of abnormality.。