Key Points on Full-Process Compliance Practice and Risk Avoidance for Payment in Transfer Trade

Core Business Logic and Scenarios of Transfer Trade Payment

Transfer trade refers to the trade mode where goods purchased from a third country are directly shipped to the destination country without going through customs declaration for import in China.The payment link involves two-way settlement: the domestic entity pays the goods to the overseas supplier,and collects the goods from the buyer in the destination country.With tightened global trade rules in 2026,most countries have strengthened verification of the authenticity of documents and transaction backgrounds for transfer trade.Enterprises often face risks such as penalties from SAFE,exchange losses,even cargo detention due to ignoring payment compliance requirements.

Two Typical Scenarios of Transfer Trade Payment

• Domestic enterprises act as intermediaries,signing purchase contracts with overseas suppliers and sales contracts with buyers in the destination country.The payment is first transferred from the buyer in the destination country to the domestic account,and then paid by the domestic enterprise to the overseas supplier
• Domestic enterprises entrust third-party agencies to handle payment,only responsible for order docking,and need to ensure that the agency has complete import and export qualifications and SAFE filing

Compliance Red Lines and Risk Warnings for Transfer Trade Payment in 2026

Major trading countries around the world have upgraded their supervision on transfer trade in 2026: the European Union has implemented an electronic network verification system for certificates of origin,U.S.Customs has added requirements for verifying warehousing records at transit ports,and China’s SAFE has included transfer trade payment in its key monitoring list.The following are three types of high-frequency violation risks:

• Risk of Inconsistent Documents: The descriptions,quantities,and unit prices of bills of lading,commercial invoices,and certificates of origin must be completely matched.A transfer trade case was seized at Shanghai Port in 2025,where the description on the bill of lading differed from the certificate of origin by the first 6 digits of the HS code.It was identified as fictitious trade by SAFE and fined 4% of the payment amount
• Risk of Mismatched Payment Subject: If a domestic enterprise fails to make payment through its own current account for foreign exchange and entrusts an unqualified entity to make the payment,SAFE will require the payment to be returned and include the enterprise in the regulatory list
• Risk of Improper Anti-Dumping Avoidance: Forging certificates of origin from third countries to avoid anti-dumping duties in the destination country.In 2026,the EU will impose a 5-year import and export ban on enterprises that forge documents and recover the difference in anti-dumping duties

Practical and Implementable Steps for Transfer Trade Payment

In line with 2026 regulatory requirements,transfer trade payment must strictly follow the following process,and paper and electronic vouchers must be retained for at least 5 years at each step:

• Complete trade subject filing in advance: Domestic enterprises need to complete transfer trade income and expenditure filing on the SAFE online service platform.For new third-country transit business,a transaction background description must be submitted 3 working days in advance
• Accurately classify HS codes: The HS code of transferred goods must match the tariff policies of both China and the destination country.In 2026,RCEP member states require that the HS code of transferred goods is consistent with the declaration on the certificate of origin; otherwise,tariff preferences cannot be enjoyed
• Review the full set of payment documents: Including purchase contracts,sales contracts,bills of lading,transit port warehousing certificates,and certificates of origin.Key check whether the “notify party” on the bill of lading is consistent with the buyer’s information in the destination country
• Handle payment procedures in compliance: Make payment through the current foreign exchange account.If entrusting an agency,a formal agency agreement must be signed and filed with SAFE

Exclusive Service Advantages of Zhongshitong for Transfer Trade Payment

As a professional foreign trade agency headquartered in Shanghai,relying on the local resources of Shanghai Port and the linkage ability of national ports,we help enterprises solve the full-link pain points of transfer trade payment:

• Real-time supervision of 2026 tariff policies and anti-dumping warnings of various countries,adjust transit countries and payment paths in advance to avoid exchange losses
• Cross-port declaration ability across the country,enterprises can complete transfer trade filing nationwide without registering with multiple customs and SAFE
• Global agency network covers transit ports in Southeast Asia,Europe,and North America,and can assist enterprises in obtaining real transit warehousing certificates and compliant certificates of origin
• Professional risk control team reviews payment documents throughout the process,anticipates customs control risks in advance,and avoids cargo detention and payment disputes

Review of Typical Cases of Transfer Trade Payment

In 2025,a Shenzhen-based mechanical and electrical enterprise planned to transfer a batch of industrial pumps to the United States.Due to failing to check the U.S.anti-dumping duty policy on Chinese industrial pumps in advance,it entrusted an unqualified agency to handle payment,resulting in the goods being detained by U.S.Customs after payment,with a loss of about RMB 800,000.After we intervened,we assisted the enterprise in re-selecting Malaysia as the transit country,handling a compliant certificate of origin,and adjusting the payment subject to the filed agency.Finally,customs clearance and payment rectification were completed within 12 working days,and all losses were recovered.

Transfer trade payment is not a simple fund transfer,but involves multi-dimensional compliance requirements of customs,SAFE,and the destination country’s customs.The regulatory environment will continue to tighten in 2026.Enterprises must abandon the idea of “valuing business over compliance” and entrust professional institutions to control the payment link throughout the process to avoid losing much for a little.