In-depth Dissection of Full-Link Risk Points of Zhangjiagang Transit Trade, Compliance Red Lines Investigation One by One

1.Customs Blacklist Alert: Hidden Risk Areas for Transit Trade

In 2026,Zhangjiagang Customs has comprehensively upgraded its monitoring of transit trade,focusing on goods traded with sensitive countries or regions.Once goods are included in the customs blacklist,it will directly trigger port-wide inspection and control,which will not only incur high demurrage and inspection fees,but may also lead to cargo detention and enterprise credit downgrade.

In 2025,a chemical enterprise in Zhangjiagang failed to check the compliance qualification of the transit country in advance as its transit goods involved countries on the sanction list,resulting in the goods being detained at Zhangjiagang Port for 12 days with a demurrage of 180,000 yuan.The enterprise was also included in the customs key monitoring list,and all its goods were subject to 100% inspection and control within the following 6 months.Relying on the national port linkage network,Zhongshitong assisted the enterprise in completing the blacklist appeal process,and adjusted the transit route to Singapore,finally restoring normal customs clearance authority.

2.False Declaration of HS Code: Core Compliance Red Line for Transit Trade

HS code is the core carrier of transit trade compliance.In 2026,the customs AI price review system has realized intelligent comparison of codes for transit goods.False or incorrect declaration will directly trigger retroactivity of anti-dumping duties and administrative penalties from customs.Especially for electromechanical products,Zhangjiagang Customs will synchronously connect with the data of the electromechanical administrative office to verify the compliance of product classification.

In practice,note that the HS code of transit goods must fully match the goods description on the certificate of origin,transit warehouse voucher and bill of lading.For multi-purpose equipment,it is necessary to apply for pre-classification from customs in advance to avoid risks caused by code ambiguity.Zhongshitong has a professional classification team,which can make advance prediction based on the price review model of Zhangjiagang Port to ensure code compliance.

3.Document Consistency: Dual Verification of Property Right and Compliance

The document chain of transit trade involves multiple documents such as certificate of origin,transit warehouse bill of lading,final destination port bill of lading,packing list,etc.Any inconsistency may lead to property right disputes or customs penalties.The following is a comparison between compliant and non-compliant documents:

For document review,the following core steps must be strictly implemented:

• Verify that the goods description on the certificate of origin is fully consistent with the detailed expressions on the bill of lading and packing list,and vague words such as "etc.","similar" are prohibited
• Confirm that the transit warehouse voucher is a real document issued by the official agency of the transit country to avoid compliance risks of virtual transit
• Verify that the shipper and consignee information on the bill of lading fully matches the subject of the foreign exchange settlement account,and eliminate the disconnection between capital flow and cargo flow

4.Foreign Exchange Compliance: Bottom Line of Capital Security for Transit Trade

In 2026,the State Administration of Foreign Exchange has further tightened the supervision of payment and receipt of foreign exchange for transit trade,explicitly requiring that the time difference between payment and receipt of foreign exchange for transit trade shall not exceed 90 days,and the deviation between the amount of payment and receipt of foreign exchange and the cargo value shall be controlled within 5%.In case of violation,the enterprise will be suspended from foreign exchange settlement authority,and even face administrative penalties for foreign exchange.

In practice,note that the use of third-party personal accounts for foreign exchange receipt and payment is prohibited,and settlement must be completed through the corporate public account.At the same time,a complete document chain shall be retained as foreign exchange verification vouchers,including certificate of origin,transit bill of lading,final destination port bill of lading,etc.Zhongshitong has a global foreign exchange agency network,which can assist enterprises in selecting the optimal settlement currency to avoid exchange loss risks.

5.Risk Control Early Warning System: Pre-event Prevention + In-event Response + Post-event Remediation

Risk prevention and control of transit trade requires the construction of a closed-loop system covering the whole process of pre-event,in-event and post-event stages:

Pre-event Prevention: Real-time monitor the changes of anti-dumping policies in destination countries.In 2026,the EU’s anti-dumping duty on Chinese electromechanical products has been raised to 42%,so it is necessary to adjust the transit route to RCEP member countries such as Malaysia and Thailand in advance,and use the certificate of origin to reduce or exempt tariffs.

In-event Response: If goods are subject to inspection and control at Zhangjiagang Port,provide a complete document chain as soon as possible to cooperate with customs inspection,and contact a professional agency to assist in the appeal.Zhongshitong can rely on the resources of its Shanghai headquarters to coordinate the inspection process of Zhangjiagang Customs and shorten the detention time.

Post-event Remediation: If goods are detained due to compliance issues,immediately launch the objection appeal process,and adjust the transit route or goods classification.In 2025,a machinery enterprise in Zhangjiagang was penalized by customs for incorrect code declaration.Zhongshitong assisted it in completing the code correction and submitted an objection appeal,finally reducing the penalty amount by 80%.

As a foreign trade agency headquartered in Shanghai,Zhongshitong can realize cross-regional declaration at ports nationwide,and solve cross-regional transit trade problems through the coordination of its global agency network,building a solid compliance firewall for enterprises.