How Dairy Product Import Agencies Can Mitigate Customs Valuation Risks

Core Compliance Key Points for Dairy Product Import Agencies: A Full-Process Analysis from Valuation to Quarantine

Against the backdrop of global dairy supply chain adjustments in 2026,importers have significantly raised their requirements for the professionalism of agency companies.As a service provider with 20 years of experience at Shanghai ports,Zhongshitong once encountered a case where a multinational enterprise faced customs clearance delays due to incorrect declaration of imported dairy products.A batch of cheese imported from Europe was misclassified under HS code 0401.20.00 (fresh cream) instead of the correct code 0406.30.00 (cheese products).After being inspected by customs,the goods were detained at the port for 3 days,resulting in direct losses of over 80,000 yuan in demurrage and storage fees.This case reveals that dairy product import agency is by no means a simple "door-to-door delivery" service; instead,it requires precise control over every operational node within a compliance framework.

I.Customs Valuation: "Minefields" and Solutions for Dairy Product Price Declaration

Customs review of the dutiable value of dairy products usually follows the "transaction value method",which is based on the actual transaction value of imported goods.If the declared price deviates by more than 5% from the "benchmark price" in the customs system (such as the EU Dairy Export Price Index,US FDA Price Database),inspection or valuation adjustment will be triggered.The "Commodity Price Dynamic Comparison System" newly launched by the General Administration of Customs (GAC) in 2026 can automatically capture the importer’s declaration data from the past 12 months and conduct horizontal comparisons with similar products,which means:

• Risk Point 1: Conflict between declared price and certificate of origin - A Russian dairy product importer was determined by customs to have "unreal transaction value" because the declared price was lower than the FOB price shown on the certificate of origin,and finally paid an additional tax of 120,000 yuan based on the "average price of similar products" released by GAC.
• Risk Point 2: Failure to declare cold chain transportation costs separately - New regulations in 2026 require that international refrigeration transportation costs for imported dairy products must be listed separately (accounting for 3%-8% of the total declared price).Failure to declare separately may be classified as "evasion of supervision".

Solution: Upon receiving a dairy product import order,Zhongshitong submits a "Price Declaration Pre-Review Form" to customs 72 hours in advance,attaching the certificate of origin,exporter’s commercial invoice,and customs classification cases for the same batch of products in the past 3 months,ensuring that the error between the declared price and the customs benchmark price is controlled within ±3%.

II.Commodity Inspection Pre-Review: "Double Insurance" for Dairy Product Labels and Quality

According to Article 67 of the Food Safety Law,imported pre-packaged dairy products must have Chinese labels that meet the requirements of "true,standardized,and complete content".Among the imported dairy products handled by Zhongshitong,about 30% of the labels have "hidden risks".For example,a batch of Australian milk powder was directly returned at Shanghai port because the label did not indicate "allergen warning" (containing trace nut ingredients).The newly added "Label Pre-Review Green Channel" in 2026 requires:

III.Animal and Plant Quarantine: "National Border Defense" for Dairy Products

Dairy products fall into the category of "animal-derived food" and must comply with Article 4 of the Law of the People’s Republic of China on Entry and Exit Animal and Plant Quarantine.The newly added "Risk Classification System for Animal-Derived Products" in 2026 classifies dairy products into three levels (A/B/C) based on the epidemic risk of the producing country: Level A (e.g.New Zealand,Australia) can be "directly released after inspection",while Level C (e.g.some areas in Brazil) requires "100% laboratory testing".In practice,agency companies should focus on the following key points:

• Verification of exporting country qualifications - Requires foreign exporters to provide an "Official Veterinary Health Certificate" with the "production factory registration number" (e.g.EU dairy products must correspond to the regulation number EU No.875/2004).
• Cold chain temperature traceability - Refrigerated containers carrying dairy products must provide "temperature sensor records" (in 2026,customs requires accuracy of ±0.5℃ and 24-hour continuous monitoring).Any deviation from 0-4℃ at any time will trigger suspicion of "physical contamination".

Real Case: A batch of milk powder imported from a Southeast Asian country could not obtain the "Inspection and Quarantine Certificate for Entry Goods" after arriving at the port because the production factory was not registered in the "Catalogue of Entry Animal-Derived Food Production Enterprises in China".Zhongshitong coordinated with Shenzhen Customs to issue a "Temporary Release Certificate" through "inter-port linkage",enabling the goods to complete the supplementary registration of the production factory within 48 hours.

IV.Import License: "Entry Ticket" and Time Limit Management for Dairy Products

The 2026 revised "Dairy Product Import Tariff Adjustment Plan" clearly states that imported infant formula milk powder requires an additional "Automatic Import License" (supervision code 71),while other dairy products (such as adult milk powder,cheese blocks) are managed through the "Import Animal and Plant Quarantine License" (code P).The core differences between these two types of licenses are as follows:

Special Reminder: All dairy product import agencies must mark the "final destination" and "production factory" on the "Import License Approval Form".In 2026,customs has added "destination inspection".If the goods are actually shipped to Location A but declared as Location B,it will be judged as "unlicensed transportation".

V.Risk Warning: Hidden Costs That Cannot Be Ignored in Dairy Product Agency

In addition to the above compliance risks,Zhongshitong has identified three typical "hidden traps" in dairy product agency in 2026:

• Document Switching Fee Trap - Freight forwarders may charge "document amendment fees" (1,500-3,000 yuan per set of documents) during the "bill of lading replacement" process.Zhongshitong can reduce this cost by 60% through the "Electronic Bill of Lading Direct Release System".
• Label Rectification Fee - If labels need to be reprinted,additional "label design fees" (including customs template review) are required.Zhongshitong recommends that customers complete the final label review before import to avoid secondary investment.
• Storage Demurrage Fee - Dairy products are "high-value perishable goods".The average port detention cost in 2026 is 0.8 yuan per carton per day (e.g.demurrage for 500 cartons of cheese is about 400 yuan per day).Applying for "demurrage exemption" in advance can effectively avoid this cost.

Conclusion: In 2026 dairy product import trade,the value of agency companies lies not only in "customs clearance efficiency",but also in transforming "compliance risks" into "competitive advantages".With accumulated experience from over 2,000 dairy product import cases,Zhongshitong has formed a standardized process of "3-day pre-review,5-day customs clearance,7-day release",helping customers achieve dual guarantees of "compliance safety" and "commercial value" in the global supply chain.