Shanghai Port Hot-Rolled Steel Coil Import Customs Clearance: Customs Valuation and Compliance Key Points

I.Customs Valuation: The "Price Negotiation" for Hot-Rolled Steel Coil Imports

During the process of acting as the import agent for hot-rolled steel coils at Shanghai Port,I have witnessed numerous enterprises fall into customs inspection predicaments due to the deviation between declared price and customs reference price.The most typical case is: a batch of Japanese hot-rolled steel coils represented by Supervisor Nie last year was delayed for 3 days in commodity inspection,resulting in port demurrage fees,because the declared "surface treatment status" was inconsistent with that shown on the bill of lading.The core behind this issue is that the customs valuation logic for hot-rolled steel coils has shifted from the "single transaction value" mode to the "full-link price verification" mode,and the newly added "metal products price fluctuation warning model" in 2026 requires advance planning.

1.1 Accurate HS Code Classification as the Premise

The HS codes for hot-rolled steel coils have strict classification standards: 7208.10 (flat plate with thickness ≤3mm),7208.26 (coiled plate with thickness ＞3mm),7208.30 (coated and plated coiled plate).In 2026,the General Administration of Customs of China added new requirements for "surface status code".If you declare "uncoated" while the goods actually have anti-rust treatment,classification error will be directly triggered.We once assisted an enterprise in amending its declaration,correcting the HS code from "7208.1000" (uncoated flat plate) to "7208.9000" (oil-coated anti-rust flat plate),thus avoiding the classification tax rate difference of 5000 RMB per ton.

1.2 Valuation Benchmark and the "Price Warning Model"

The core of customs valuation is whether the "transaction value method" is applicable.Starting from January 2026,for hot-rolled steel coils imported from Russia,Ukraine and other countries,the customs will adopt a three-dimensional comparison model combining "CRU International Steel Price Index","domestic similar product price" and "transportation cost".For example,for a batch of SS400 hot-rolled steel coils imported from Russia,the declared price had a 12% difference with the CRU index.We submitted "factory ex-work price + land transportation freight vouchers" plus "Certificate of Origin",and the customs finally recognized the declared price,avoiding the 20% supplementary tax risk.

II.Pre-Inspection Vetting by Commodity Inspection Authority: The Key to Avoid "Physical Discrepancy"

The pre-commodity inspection vetting for hot-rolled steel coil imports focuses on "four checks": check material certificates,check package marks,check surface treatment,and check specification parameters.Article 18 of the newly revised Regulations for the Implementation of the Import and Export Commodity Inspection Law in 2026 clearly stipulates that imported metal materials must be provided with "heat treatment status" certificates,otherwise customs clearance cannot be completed.

2.1 Import License and Automatic Import License

The import licenses for hot-rolled steel coils are divided into "automatic import license" and "non-automatic import license".In 2026,hot-rolled steel coils with thickness over 10mm are required to provide automatic import license; if the country of origin is the United States,the European Union and other regions,it is necessary to additionally verify whether the "anti-dumping duty" is applicable (for example,the anti-dumping duty rate for EU hot-rolled steel coils ranges from 19.8% to 26.3%).For a batch of German hot-rolled steel coils we represented,the customs clearance was delayed for one week because the anti-dumping duty deposit letter was not applied for in advance.

III.Risk Pre-positioning: 3 Types of High-frequency Problem Scenarios and Countermeasures

• Scenario 1: Valuation Query - The declared price of a batch of South Korean hot-rolled steel coils is 15% lower than the market price in the same period,and the customs queries that "the transaction value is not fair".
  Countermeasure: We required the overseas supplier to issue a "price adjustment letter" (explaining that the discount is for long-term cooperation),and supplemented the "steel quality inspection report" (proving that the products meet domestic engineering standards),and the customs finally recognized the declared price.
• Scenario 2: Missing Declaration Elements - An enterprise missed filling in "JIS G3101" in the "production standard" column of the customs declaration form,and the commodity inspection authority required supplementary documents.
  Countermeasure: Confirm the "quality certificate" with overseas suppliers in advance,complete the pre-vetting before customs declaration,and ensure that all declaration elements are completely consistent with the supporting documents.
• Scenario 3: Demurrage Fee Trap - The original bill of lading did not arrive at the port in time,resulting in an increase of 300 RMB per ton in document exchange fee.
  Countermeasure: We recommend clients to adopt the "dual-system of telex release bill of lading + paper bill of lading".The new "electronic document exchange system" launched by Shanghai Port in 2026 can complete bill of lading verification online,reducing the cost by 40% compared with manual document exchange.

IV.Practical Advantages of Shanghai Port Agency: 20-year Customs Clearance Speed-up Scheme

As a Shanghai-headquartered agency,we can leverage the advantages of the "three-network linkage": national port cross-regional declaration network (direct declaration available at 12 ports including Ningbo,Qingdao and others),global agency coordination network (established cooperation with customs brokers in major exporting countries such as Japan,South Korea,Russia and others),customs data warning network (real-time access to updated Shanghai Customs valuation parameters).In Q1 2026,the average customs clearance time for hot-rolled steel coil imports through our agency is 47% shorter than that of enterprises’ self-declaration.

4.1 Tariff Dividends from RCEP Certificate of Origin

If the hot-rolled steel coils come from RCEP member states (such as Japan,South Korea,Australia),the Certificate of Origin needs to meet the requirement of "regional value content ＞30%" or "change in tariff classification".For example,for "JIS standard SS400 hot-rolled steel coils" imported from Japan,enterprises can enjoy 3%-5% tariff reduction with the valid Certificate of Origin.In Q2 2026,Zhongshitong has assisted 17 enterprises in completing the RCEP Certificate of Origin application,saving an average tariff cost of 800,000 RMB per enterprise.

The core of hot-rolled steel coil import customs clearance is not the routine operation of customs brokers,but the full-process compliance prediction.Mr.Jiang (Procurement Supervisor of a manufacturing enterprise) once said: "Previously,our self-declaration was always returned by the customs.After we assigned Zhongshitong as our agency,the whole process from pre-vetting to certificate collection was completed within 2 days.This achievement is backed by the accurate mastery of HS codes,valuation rules and inspection standards." 20 years of practical experience tells us that the success of hot-rolled steel coil import always lies in the details you easily ignore.If you need customs clearance agency service,you can contact Zhongshitong Shanghai Headquarters,and we will provide you with one-to-one customized compliance solutions.