Practical Guide to Entire Process of Chinese Manufacturing Transshipment Trade Under Bulgaria Anti-Dumping Context

Bulgaria Anti-Dumping in 2026: Breakout Path for Chinese ManufacturingIn March 2026,the Bulgaria Trade Commission officially issued a final ruling on anti-dumping against Chinese-made carbon steel fasteners and power tool accessories,imposing anti-dumping duties ranging from 42% to 51%,directly covering nearly 30% of China’s total exports to Bulgaria.Many factories have directly received suspension orders from Bulgarian importers,and some goods that have already been shipped face port congestion fines.In this context,transshipment trade has become the core solution for compliant avoidance of anti-dumping duties,but there are still many hidden risks in practical operation.### 1.Core Impacts of Bulgaria’s Anti-Dumping PolicyDifferent from the EU’s unified anti-dumping measures,as an EU member state,Bulgaria’s anti-dumping duties need to comply with EU trade rules at the same time,but can adjust the tax rate range separately.The current round of anti-dumping in 2026 targets categories such as HS Codes 85013100 and 73181500.When enterprises export directly to Bulgaria,importers need to pay additional anti-dumping duties equal to 47% of the goods value,leading to a nearly 60% increase in terminal price and complete loss of price competitiveness.In addition to the surge in tariff costs,direct exports will also trigger targeted inspections by Bulgarian Customs,focusing on verifying the consistency of Certificate of Origin,declaration elements and physical goods.Once inconsistencies are found,not only will the goods be detained,but also the enterprise will be included in the EU Customs’ early warning list,affecting subsequent customs clearance at all EU ports.### 2.Compliance Practical Framework of Transshipment TradeThe core logic of transshipment trade is to transfer goods through a third country,replace the Certificate of Origin,and mark the origin of goods as the third country,so as to avoid Bulgaria’s anti-dumping duties.The mainstream transit countries in 2026 include Thailand,Malaysia,Vietnam,etc.among which Thailand’s FORM E Certificate of Origin can enjoy tariff preferences under both ASEAN and Bulgaria,making it the optimal choice at present.The following are core compliance steps of transshipment trade:<ul>- Accurate HS Code Classification: Avoid mixing high-tax-rate categories with low-tax-rate categories for declaration.Need to adjust declaration elements according to HS Code notes of Bulgarian Customs- Third-Country Transit Filing: Select cooperative factories with actual production capacity,not shell companies,to ensure the authenticity of the Certificate of Origin is verifiable- Separation of Document Flow and Cargo Flow: Complete document exchange through a third-party freight forwarder to avoid direct exposure of Chinese exporter’s information- Compliant Foreign Exchange Settlement: Complete foreign exchange settlement through a third-country cooperative account,avoiding direct association with Bulgarian importers’ accounts### 3.Practical Case: Transshipment Breakout of a Hardware FactoryIn May 2026,a Shanghai-based hardware fastener factory (hereinafter referred to as Factory A) received a notice from a Bulgarian importer that it could not continue to place orders due to anti-dumping duties.Two containers of goods produced earlier faced port congestion risks.After Zhongshitong received the commission,it implemented the following operations:**Situation**: Factory A’s directly exported carbon steel fasteners were subject to 47% anti-dumping duty in Bulgaria,with a goods value of 1.2 million RMB,and port congestion charges accumulated to 3,000 Euros per day.**Task**: Complete transshipment operations within 10 days,avoid anti-dumping duties,and ensure smooth customs clearance and payment collection for goods.**Actions**:

• Coordinate with a cooperative factory in Thailand to complete simple assembly (replace packaging labels) and apply for Thailand’s FORM E Certificate of Origin;
• Adjust HS Code declaration elements,changing "originated in China" to "originated in Thailand";
• Arrange sea shipment from Shanghai Port to Laem Chabang Port in Thailand,then transship to Varna Port in Bulgaria;
• Complete foreign exchange settlement through a Thailand cooperative account to avoid direct settlement risks.**Result**: The goods cleared customs smoothly in Bulgaria,only paying 12,000 Euros for Thailand transit.Compared with anti-dumping duties,it saved 564,000 RMB,and shortened the payment collection period by 15 days.### 4.Cost Comparison and Risk WarningsThe following is a cost comparison table of direct export and transshipment trade:

Hidden risks to note include: qualification fraud of third-country shell companies,document exchange fee traps (some freight forwarders overstate transit fees),and loss of cargo rights due to inconsistency between document flow and cargo flow.Zhongshitong’s risk control system will verify the actual production capacity of third-country partners in advance,monitor the entire cargo flow,and ensure that each operation complies with international trade rules in 2026.### 5.Local Advantages of Shanghai PortAs a local foreign trade agency in Shanghai,Zhongshitong has priority inspection channels at Shanghai Port,which can quickly complete customs clearance and document exchange procedures for transshipment goods.Meanwhile,our global agency network covers transit countries such as Thailand,Malaysia,Vietnam,etc.and can simultaneously complete Certificate of Origin processing,transit customs clearance and other operations,without enterprises coordinating across regions.Whether it’s cross-border declaration at domestic ports or logistics coordination of global routes,it can be completed in one stop.Finally,remind all export enterprises: Anti-dumping transshipment trade is not a gray area.As long as strictly complying with third-country origin rules and consistency between document flow and cargo flow,trade barriers can be compliantly avoided.Never use false documents or shell companies,otherwise you will face lifetime early warning from EU Customs and affect export business to all EU markets.