Full Process Compliance Guide for Foreign Exchange Collection and Payment in Transit Trade

In 2026,global trade protectionism is on the rise.The anti-dumping duties imposed by Europe and the United States on Chinese products such as machinery and electronics,chemicals,etc.have generally risen to over 20%.Transit trade has become a core choice for many foreign trade enterprises to avoid tariffs and expand overseas markets.However,many enterprises get stuck in the foreign exchange collection and payment link: either rejected by banks due to inconsistent documents,or charged hidden fees by middlemen,or even touch the red line of foreign exchange supervision.As a foreign trade agency headquartered in Shanghai,over 60% of the transit trade orders we have handled have encountered problems in foreign exchange collection and payment.This article will dissect practical details and risk control points.

Compliance Logic and Practical Points for Foreign Exchange Collection in Transit Trade

The core of foreign exchange collection in transit trade is to comply with the principle of "who exports,who collects foreign exchange" of the State Administration of Foreign Exchange (SAFE),and also needs to match the consistency of customs declaration documents.In 2026,SAFE upgraded the transit trade monitoring system,which will compare the consistency of foreign exchange collection amount,transit contract,and bill of lading information.Any inconsistency will trigger an early warning.

List of Required Documents for Foreign Exchange Collection

• Transit sales contract signed with the middleman in the transit country
• Certificate of origin issued by the transit country (for example,members of the Regional Comprehensive Economic Partnership (RCEP) can apply for FORM E to enjoy preferential tariffs)
• Full set of through bill of lading (must reflect transit port information)
• Export customs declaration form (domestic enterprise declares as the shipper)

Here is a practical detail: In 2025,a machinery and electronics enterprise in Suzhou exported to the United States via Singapore as transit.When collecting foreign exchange,the bank required a power of attorney agreement between the domestic enterprise and the middleman because the shipper on the bill of lading was the Singaporean middleman,otherwise it would reject the remittance.Later,by uploading the power of attorney agreement to the SAFE register in advance,the foreign exchange collection was successfully completed.

A red line to note: Fabricating transit trade is strictly prohibited.For example,there is no actual goods passing through the transit port,only passing through the middleman’s accounts.In 2026,SAFE increased the penalty for such false transit trade to 30% of the amount involved,and will include the enterprise in the key foreign exchange supervision list.

Path Selection and Cost Control for Foreign Exchange Payment in Transit Trade

There are two main modes of foreign exchange payment in transit trade,with significant differences in compliance risks,costs and timeliness.We compare them in the table below:

The direct payment mode requires the domestic enterprise to sign a purchase contract directly with the supplier in the producing country.When making payment,documents such as purchase invoice and packing list need to be provided,and the payment amount must be consistent with the FOB value of the export customs declaration.In 2026,the price verification system of Shanghai Customs added a transit trade payment comparison module,which will automatically check the difference between the payment amount and the customs declaration.A difference of more than 5% will trigger a controlled inspection.

The payment through middleman mode is common when the transit country has advantages in handling certificates of origin,but it should be noted that the middleman may charge additional storage fees and document exchange fees.For example,in 2026,the document exchange fee at Dubai transit port is generally between 300-500 US dollars,and some unscrupulous middlemen will also hide demurrage fees.A chemical enterprise in Shenzhen was overcharged 1200 US dollars in storage fees by the middleman in a transit trade order in 2025.Later,through our Dubai agent network negotiation,800 US dollars of unreasonable fees were recovered.

Core Risk Control Measures for Foreign Exchange Collection and Payment in Transit Trade

• Pre-audit documents: Submit all documents to a professional agent for review 1-2 working days before foreign exchange collection and payment to avoid inconsistency warnings from banks or customs
• Lock lump-sum payment fees: When signing a contract with the middleman,clarify the lump-sum price of all transit-related fees to avoid hidden charges
• Avoid sensitive remittance paths: In 2026,the U.S.Office of Foreign Assets Control (OFAC) added 3 transit countries to its sanction list.It is strictly prohibited to conduct foreign exchange collection and payment through banks in sanctioned countries
• Retain complete document chain: All documents from purchase contract to sales contract,bill of lading,and certificate of origin must be retained for at least 5 years for inspection by SAFE or customs

In addition,for transit trade at Shanghai port,our advantage lies in providing a green channel for off-site customs declaration.For example,if an enterprise ships from Shenzhen,it can complete transit customs declaration at Shanghai port without personally going to Shanghai to handle procedures.At the same time,relying on our global agent network,we can complete the quick processing of certificates of origin in the transit country,which is 30% faster than the enterprise handling it by itself.

Common Pitfalls and Avoidance Guidelines for Foreign Exchange Collection and Payment in Transit Trade

The first type of pitfall is inconsistency between the foreign exchange collection currency and the customs declaration currency.Some enterprises choose to collect foreign exchange in a third currency to avoid exchange rate risks,but in 2026,SAFE requires that the foreign exchange collection currency must be consistent with the customs declaration currency.Otherwise,an exchange rate fluctuation statement must be submitted,otherwise it will be required to return and remit again.

The second type of pitfall is failure to register the middleman’s collection of foreign exchange.Some enterprises entrust middlemen to collect foreign exchange on their behalf but do not register with SAFE,which will be identified as illegal foreign exchange collection and require supplementary payment of foreign exchange income.

The third type of pitfall is demurrage caused by delayed payment.If the goods of transit trade stay at the transit port for more than 7 days,high demurrage fees will be generated.It is necessary to agree on a free storage period with the freight forwarder in advance,generally 3-5 days.

Finally,remind enterprises that the core of transit trade is "authenticity and compliance".Do not choose unqualified middlemen to save agency fees.Once compliance problems arise,not only will the payment be lost,but also the enterprise’s foreign exchange register qualification will be affected,and even be included in the customs dishonesty list.