Can re-export trade obtain compliant and valid customs declaration forms after transaction completion
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I am a small merchant engaged in re-export trade of auto parts in Southeast Asia. I have just completed three transactions of re-exporting goods from Thai factories to the EU recently. The goods do not enter the bonded warehouse in China throughout the whole process, and are directly transshipped and departed from Thai ports.
When handling cross-border foreign exchange settlement now, the bank requires me to provide corresponding customs declaration documents to complete the settlement. I heard from peers before that re-export trade does not require customs declaration, so I did not prepare any customs declaration related documents throughout the process.
Now the foreign exchange settlement process has been stuck for nearly half a month, the funds cannot be received, the upstream factory is urging for payment, and the downstream customer is also following up the progress. I am extremely anxious and want to ask: does re-export trade have customs declaration forms at all? Under what circumstances can I get the declaration form? How can I solve the document problem in my case?
DanielYears of service：8Customer Rating：5.0
Legal AdvisorStart a Chat
Many re-export trade practitioners have two cognitive misunderstandings: first，they believe that all re-export trade does not require customs declaration and will definitely not have customs declaration forms，second，they believe that customs declaration forms are mandatory for re-export trade foreign exchange settlement，and absence of such forms means non-compliance. These two wrong understandings often directly lead to business stagnation and even trigger compliance risks.
For third-country re-export where the goods never enter China's customs territory throughout the process，there is indeed no need to declare to China's customs，so naturally no formal customs declaration form issued by China's customs will be obtained. For re-export trade where the goods enter China's special supervision areas such as bonded zones and bonded logistics centers，it is necessary to declare to the customs according to regulations，and corresponding entry filing lists or customs declaration forms will be obtained.
The chain reaction caused by cognitive errors is very clear: if goods enter special supervision areas but are not declared according to regulations，it will directly lead to port detention of goods，and will also be marked as abnormal and non-compliant by the customs，if you forge customs declaration forms to meet settlement requirements for non-entry re-export trade，it will trigger compliance early warnings from banks and customs，and you may even be included in the blacklist for foreign exchange receipt and payment，affecting all subsequent cross-border businesses.
Clarify in advance whether the re-export route enters China's customs territory，and communicate the document requirements with the account-opening bank before operation，so that risks can be isolated from the source. For the already occurred foreign exchange settlement stagnation，providing transshipment bills of lading，loading and unloading records at the transshipment port，and trade contracts is sufficient to complete the compliance filing. There is no need to force the provision of customs declaration forms，and the settlement block can be resolved quickly.
SarahYears of service：3Customer Rating：5.0
Foreign Exchange AdvisorStart a Chat
In terms of the requirements for customs declaration documents for re-export trade, current customs rules clearly stipulate that re-export trade where goods do not enter China's customs territory does not require import or export declaration, so naturally no formal customs declaration form issued by China's customs will be generated. Only when goods enter China's domestic special supervision areas, such as bonded zones, export processing zones, etc. for transshipment, storage and distribution, is it necessary to make entry or exit declaration, and corresponding entry filing lists or formal customs declaration forms will be generated.
If document abnormality occurs due to incorrect declaration information and the documents cannot be normally used for foreign exchange settlement or compliance verification, you can apply for deleting the original declaration and re-declaring. Supplementing materials such as re-export trade contracts, ownership certificates, transshipment agreements and other materials as required by the customs can complete the document modification operation and restore the validity of the documents. In case of price review disputes, providing the original purchase invoice at the transshipment port and the ownership transfer agreement can complete the proof, which will not affect the validity of the documents, nor will additional non-compliance penalties be imposed.
CharlotteYears of service：4Customer Rating：5.0
Currency Exchange AdvisorStart a Chat
The documents of re-export trade are directly related to the logistics route. Choosing different transshipment schemes will lead to completely different results on whether there is a customs declaration form. If direct transshipment is selected, the goods do not enter the customs territory of the transshipment country/region and are directly transshipped at the port, no customs declaration form of the transshipment country will be generated, and no customs declaration operation is required in China.
If entry transshipment is selected, the goods enter the storage area of the transshipment port, it is necessary to declare according to the local customs rules, and corresponding customs declaration documents will be generated. When operating re-export trade, you need to confirm the document requirements of the transshipment scheme in advance according to the requirements of ownership transfer, and confirm with the freight forwarder in advance whether a transshipment certificate is required, so as to avoid blocked ownership transfer or foreign exchange settlement due to lack of documents. In case of transshipment or port change, you need to ask the freight forwarder to issue a new transshipment record in time, and supplement it to the bank and customs to solve the document problem.
JohnYears of service：6Customer Rating：5.0
Export Tax Rebate AdvisorStart a Chat
Whether re-export trade has a customs declaration form will directly affect the declaration and planning of cross-border taxation. For non-entry re-export trade, there is no customs declaration form of China, so there is no need to pay value-added tax and customs duty in China, nor does it involve export tax refund. You only need to complete the declaration in accordance with the relevant requirements for non-resident enterprise income.
For re-export trade entering bonded zones, with corresponding customs declaration forms, you can apply for VAT deferral, reasonably save capital occupation costs, and also use tax differences to obtain more benefits. It should be noted that for re-export trade without customs declaration forms, you should also keep complete trade contracts, receipt and payment vouchers, and ownership certificates to cope with the follow-up verification of tax authorities, so as to avoid being identified as non-compliant due to incomplete data and incurring additional tax costs.
RobertYears of service：6Customer Rating：5.0
Warehouse Management AdvisorStart a Chat
Customs declaration forms are not mandatory for foreign exchange receipt and payment in re-export trade. According to current foreign exchange management rules, for non-entry re-export trade where customs declaration forms cannot be provided, providing materials that can prove the authenticity of the business, such as contracts, invoices, bills of lading, transshipment certificates, etc., can handle foreign exchange receipt, payment and settlement normally.
If you use CIPS cross-border RMB payment, submitting the business authenticity certification materials to the bank in advance can also complete the settlement smoothly, and will not be rejected due to the absence of customs declaration forms. If the bank has doubts about the authenticity of the business, supplementing the ownership delivery record at the transshipment port and the re-export certificate issued by the freight forwarder can complete the compliance review, and the capital flow will not be blocked. You need to communicate the business mode with the account-opening bank in advance and file for record in advance, so as to avoid delays caused by temporary supplement of materials.
DavidYears of service：3Customer Rating：5.0
Business Development AdvisorStart a Chat
If the letter of credit terms require the provision of customs declaration forms for re-export trade, you need to first confirm whether the terms are reasonable. If the goods are non-entry re-export, you should timely communicate with the applicant to modify the terms, so as to avoid being deducted fees or even refused payment due to discrepancy of the letter of credit caused by inability to provide the documents.
The ownership transfer of re-export trade can be completed by endorsement of the bill of lading, and no customs declaration form is required as the ownership certificate. When signing a re-export trade contract, you should clarify the corresponding document requirements and agree on an alternative scheme when the customs declaration form cannot be provided, so as to avoid subsequent legal disputes. If guarantee is required, a bank guarantee can replace the customs declaration form as the performance guarantee, which will not affect the validity of the contract.
WilliamYears of service：10Customer Rating：5.0
International Logistics AdvisorStart a Chat
If re-export trade goods enter China's domestic special supervision areas and involve on-site inspection, you need to prepare declaration documents, trade contracts and ownership certificates in advance to cooperate with the inspection. Complete seal is the core proof that the re-export goods have not been unpacked. You need to keep the original seal and the seal replacement record at the transshipment port, and cooperate with the customs to complete the inspection.
If there is no problem in the inspection, the customs declaration form or filing list can be issued normally. In case of abnormal machine inspection requiring unpacking inspection, sort out the cargo list and certificate of origin in advance, and cooperate with the inspectors to check the name and quantity of the goods, then the inspection process can be completed quickly, and the issuance of documents will not be affected. If you have any objection to the test report, you can apply for re-inspection, and providing the quality certificate of the original manufacturer can start the re-verification.
OliviaYears of service：5Customer Rating：5.0
Senior Customs AdvisorStart a Chat
Whether a customs declaration form is required for re-export trade is also related to the packaging attributes of the goods. For re-export of dangerous goods, no matter whether they enter the country or not, MSDS documents need to be provided to the customs of the transshipment port.
If the goods enter China for transshipment, even in the bonded zone, you also need to declare the classification of dangerous goods, and obtain the customs declaration form after completing the declaration before entering the storage area. For dangerous goods transshipped without entering the country, no customs declaration form issued by China is required, but you need to provide a copy of the customs declaration form of the original exporting country and the UN dangerous goods packaging certificate to the transshipment port and the shipping company before arranging transshipment.
For re-export of ordinary goods, the packaging only needs to meet international transportation standards, and there is no need to adjust the packaging additionally due to document requirements. Providing the corresponding packaging certificate can meet the requirements.
AlexanderYears of service：10Customer Rating：5.0
Senior Trade AdvisorStart a Chat
Non-entry re-export trade has no customs declaration form, does not involve export tax refund, so there is no need to file tax refund declaration, and it will not affect the tax refund qualification of other export businesses. For re-export trade entering bonded zones with corresponding customs declaration forms, if it meets the tax refund requirements, you can file tax refund declaration according to regulations, and you need to ensure the consistency of four flows, namely cargo flow, capital flow, contract flow and invoice flow.
When responding to tax correspondence and investigation, supplementing transshipment certificates and ownership transfer records can pass the verification. If you are suspected of capital return due to the absence of customs declaration forms, as long as you provide complete business authenticity certification materials, including transshipment bills of lading, contracts, and foreign exchange receipt vouchers, you can eliminate the doubts, and will not affect the subsequent tax refund operations.
EllaYears of service：10Customer Rating：5.0
Senior Financial AdvisorStart a Chat
When designing the supply chain structure of re-export trade, you need to clarify the document requirements in advance, and select the re-export mode according to the requirements of foreign exchange receipt and payment, taxation and compliance. If the downstream party needs a customs declaration form as a voucher, you can choose the mode of transshipment through China's bonded zone to obtain the corresponding customs declaration form to meet the requirements.
If no customs declaration form is required, choosing the third-country direct transshipment mode can save customs declaration and storage costs and improve capital turnover efficiency. You can also flexibly adjust the re-export mode according to the changes of tax difference and exchange difference, switch the operation path of whether customs declaration is required, and optimize the overall supply chain cost. It should be noted that the adjustment of re-export route must meet the compliance requirements, and false declaration to obtain customs declaration forms is not allowed, which will trigger compliance risks.