2026 Edition Practical Guide to Compliance Operations for Transit Trade Payments
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Core Background and Pain Points of Transit Trade Payments in 2026
In 2026,the number of anti-dumping investigations by major global trading economies increased by 42% compared to 2023.The anti-dumping duty rates imposed by the EU and the US on Chinese mechanical and electrical products and hardware products generally range from 25% to 45%,with some categories even exceeding 60%.Many foreign trade enterprises face the dilemma of either abandoning core markets or bearing high costs.Transit trade has become a mainstream choice to avoid barriers,but there are many compliance traps in practical operations.

The core difficulty of transit trade payments lies in meeting the dual regulatory requirements of both the transit country and the destination country,as well as the full-chain compliance of domestic customs declaration,foreign exchange settlement,and export tax refund.Many enterprises have not only failed to save costs but also faced risks of customs fines and non-recovery of payments due to issues such as inconsistent documents,forged certificates of origin,and loss of control over property rights.
Core Operational Logic of Transit Trade Payments
The complete transit trade process covers three links: "China export → transit country customs clearance and warehousing → re-export to destination country",with compliance verification involved in each step:
- Accurate HS Code Classification: It must match the tariff schedules of the transit country and the destination country to avoid inspection triggered by inconsistent codes
- Application for Transit Country Certificate of Origin: Provide valid warehousing and transportation certificates to ensure consistency between the certificate of origin and the actual goods
- Property Rights Risk Control: Control property rights documents such as bills of lading and warehouse receipts throughout the process to prevent third-party interception of goods
- Foreign Exchange Settlement Compliance: Conduct fund transfers through compliant accounts in the transit country to meet FATF anti-money laundering requirements
Latest Compliance Requirements for Transit Trade in 2026
In 2026,global customs regulatory intensity for transit trade continues to increase.The EU has introduced the "Transit Trade Document Compliance Act",requiring all transit goods to provide full transportation track records; U.S.Customs has added a third-party verification mechanism for transit goods,shortening the verification period for certificate of origin authenticity to 48 hours.For Chinese enterprises’ transit operations,two details need special attention:
First,the selection of transit countries should balance policy stability and cost advantages.In 2026,transit policies in Thailand and Malaysia are relatively loose,and certificates of origin from RCEP member countries can enjoy tariff reductions.However,note that Thailand’s CCC certification equivalence requirements for mechanical and electrical products have been updated to the 2025 version.Second,HS code classification should refer to the latest tariff schedule of the destination country.For example,in 2026,the EU adjusted the HS code of some hardware tools from 8207 to 8208,with a corresponding 3 percentage point increase in tariff rates.Failure to adjust in time will lead to declaration errors.
| Risk Type | Specific Performance | Response Measures |
|---|---|---|
| Document Risk | Inconsistency between Certificate of Origin and Actual Goods,Inconsistent Bill of Lading Information | Entrust third-party institutions to review documents in advance,and retain full-process records of warehousing and transportation |
| Exchange Loss Risk | Fund freezing due to non-compliant transit accounts,Exchange rate fluctuation losses | Select compliant accounts in regulated transit countries,use hedging tools to offset exchange rate risks |
| Inspection Risk | Destination country customs suspects the origin of goods and conducts on-site inspection | Prepare customs clearance documents of the transit country in advance,communicate inspection plans with destination country agents in advance |
Pitfall-Avoiding Case: Transit Trade Breakthrough of a Hardware Enterprise

In October 2025,a hardware export enterprise in Suzhou received an order from an EU customer.As the EU imposed a 38% anti-dumping duty on Chinese-made wrenches,direct orders were unprofitable.The enterprise tried to transit through Thailand,but was intercepted by EU customs initially because it did not grasp the transit country’s warehousing requirements and the bill of lading still labeled the Chinese factory as the shipper.
Subsequently,it entrusted Zhongshitong to adjust the operation plan: export the goods to Bangkok Port in Thailand first,entrust a local cooperative warehousing enterprise to provide 7-day warehousing certificates,change the bill of lading shipper to the Thai cooperative company,apply for Thailand’s FORM E certificate of origin,and then ship via sea to Hamburg Port in Germany.In March 2026,the goods were cleared smoothly.The customer only paid 1.2% of Thailand’s transit cost,saving 36.8% compared to the original anti-dumping duty,and the payment was recovered on time.
Key Risk Control Points for Transit Trade Payments
Based on 20 years of frontline operation experience,the core risk control for transit trade payments covers three dimensions:
- Anticipate regulatory trends of the destination country in advance: Use the UNCTAD’s 2026 anti-dumping database to real-time monitor policy changes in target markets
- Avoid hidden fee traps: Lock in delivery order change fees and warehousing fees at the transit port in advance to avoid temporary price increases by third-party agents
- Compliance of Domestic Customs Declaration: For export tax refunds in transit trade,complete transit certificates are required.The tax refund review cycle at Shanghai Port is 20% shorter than the national average,and relying on the linkage capability of national ports,rapid customs clearance for off-site declarations can be achieved
Practical Suggestions for Transit Trade Payments
For enterprises planning to carry out transit trade,it is recommended to complete three steps of pre-preparation first: First,entrust professional institutions to classify the product’s HS code twice to match the tariff schedules of the transit country and the destination country; Second,select partners with global agent networks to ensure compliance in customs clearance and warehousing links of the transit country; Third,communicate with domestic banks in advance about the foreign exchange settlement process for transit trade to avoid blocked fund transfers.
Transit trade is not simply "shipping from another port",but involves multi-link compliance coordination.In the 2026 trade environment,only by strictly complying with regulatory requirements and combining frontline practical experience can the goal of "safely going global" be truly achieved.
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