Import Customs Declaration Agent Operation Guide and Risk Mitigation Manual for Cash Against Delivery

Many new importers or enterprises that have just shifted to trade in specific target markets naturally trust the "Cash Against Delivery" (CAD) model.From their perspective,making payment only after receiving the goods,or even only after inspecting the goods,seems to be the safest way to avoid trade fraud.But as a veteran with 20 years of hands-on experience at Shanghai Port,I have to remind all practitioners: in international trade practice,especially when involving complex import customs declaration procedures,CAD (Cash Against Delivery) often hides deeper compliance risks and capital traps than T/T (Telegraphic Transfer) prepayment.The customs supervision environment in 2026 has been fully digitalized,with the China International Trade Single Window having extremely strong online verification capabilities.If your goods flow and capital flow fail to form a logically closed loop,the goods may be detained at the port and generate high demurrage fees in minor cases,and you may violate the foreign exchange control red line in serious cases.

The "Time Difference" Game Under the CAD Model

Why is CAD considered a "hot potato" in import customs declaration?The core reason lies in the time mismatch between document circulation and customs inspection.Under the conventional T/T model,the capital has already been remitted overseas,so the customs broker only needs to focus on customs clearance efficiency.However,under the CAD model,banks usually trigger the payment instruction only after receiving the original bill of lading or goods acceptance telegram.At that time,the goods may have already arrived at Shanghai Yangshan Port or Waigaoqiao Port Area after long-distance sea transportation.

This creates an extremely passive situation: if problems occur with customs valuation,commodity inspection or HS code classification after the goods arrive at the port,and the goods are put under customs control for inspection,you need to supplement additional documents or even pay deposit to get the goods released.But at this point,the payment deadline may be approaching according to the bank’s terms.If you do not make the payment,you cannot get the bill of lading to proceed with customs declaration; if you make the payment,but the goods are detained due to compliance issues,your capital will be completely exposed to risks.This dilemma has been seen too many times in several European and American mechanical equipment import cases we handled in 2026.

Customs Valuation: The Biggest Hidden Obstacle for CAD

Under the 2026 trade compliance environment,the customs’ review logic for "transaction value" has been very mature.Many clients mistakenly believe that since they adopt the CAD model,the invoice amount is the real transaction price,and the customs should recognize it directly.This is completely wrong.The customs big data system will capture the price range of similar commodities worldwide in real time.

When the declared price is lower than the system warning value,the customs will launch a price query procedure.This is particularly fatal in CAD scenarios,because the foreign exchange payment certificate is one of the necessary attachments for customs declaration.If the contract amount is obviously on the low side,and you cannot provide reasonable explanations for the price (such as brand premium,used equipment depreciation,special trade relationship,etc.),the customs will not only conduct valuation,but also suspect that you have the intention of under-declaring the price to evade taxes.Once entering the price negotiation stage,the customs clearance time will be extended indefinitely,while your bank’s deadline for retiring documents against payment is fixed.The capital pressure brought by this time difference often instantly breaks the capital chain of small and medium-sized importers.

Practical Valuation Risk Control Strategies

To avoid such situations,we will adopt pre-emptive valuation risk control when handling CAD import operations.Specifically,we must complete the pre-verification of declaration elements before the goods arrive at the port,or even before shipment.We will focus on preparing the following types of documents in advance to cope with possible customs requirements:

• Price Composition Statement: Not only the invoice,but also detailed calculation formulas including freight,insurance premium,and commission (if applicable).
• Related Transaction Certificate: If there is a special relationship between the buyer and the seller (such as parent-subsidiary company),a statement confirming that the special relationship does not affect the transaction value must be prepared in advance.
• Reference for Similar Products: Prepare sales price certificates of similar products in the domestic market or publicly released customs data of similar commodities in advance,to serve as reasonable support for the declared price.
• Foreign Exchange Payment Agreement Terms: Clearly present the logical relationship between the payment node and goods delivery specified in the CAD bank terms,to prove the consistency of capital flow and goods flow.

Document Consistency: Dual Standards from Banks and Customs AuthoritiesIn CAD business,banks require "absolute consistency" of documents,while customs requires "substantial consistency".The tiny difference between the two is often the source of trouble.For example,the goods description on the invoice is marked as "High Precision Steel Bearing",while it is abbreviated as "Steel Bearing" on the bill of lading.The bank may refuse payment due to inconsistent descriptions,or the customs may return the declaration due to incomplete filling of declaration elements (material,purpose).

In 2026,the customs declaration system at Shanghai Port has realized intelligent assistance for HS code classification.For sensitive categories such as mechanical and electrical products and chemical products,the filling accuracy of declaration elements directly affects customs clearance efficiency.When handling such businesses,our team at Zhongshitong will establish a "document center review mechanism" to ensure that the core fields including product name,quantity,amount,and country of origin on the commercial invoice and packing list provided to the bank are 100% mirrored and consistent with those on the customs declaration form submitted to the customs,leaving no ambiguous space.

Import Risk Comparison Under Different Payment Terms

To help you more intuitively understand the particularity of the CAD model in customs declaration procedures,I have sorted out a comparison table.This is not only theoretical,but a risk model summarized from countless real cases.

Real Case Review: Thrilling Moment of Mechanical Equipment Import

I recall that at the end of 2025,we took over a very tricky case.A client Manager Lu,who processes auto parts,imported a used machining center from Germany with terms of D/P at sight.Manager Lu thought this term was very safe,as he would only make payment after seeing the documents.However,after the goods arrived at Shanghai Waigaoqiao Port,they were directly put under control by the customs system.

The problem lay in the used mechanical and electrical product filing.Although the overseas supplier provided the CE certificate,no original certificate of origin was submitted,and the customs had doubts about the declared price of the 8-year-old equipment,which was marked as only 20% of the price of a new machine and considered too low.The customs requested Manager Lu to provide the original purchase invoice,foreign exchange payment record and value appraisal certificate.At that moment,the bank had sent a notice that if the payment was not made within 3 working days,it would be deemed as breach of contract,the original documents would be sent back to Germany,and the goods would face auction risk.

Manager Lu was very flustered then and turned to our team at Zhongshitong for help.After taking over the case,we immediately launched the "emergency negotiation procedure":

• First Step: Utilize our established communication channels with Shanghai Municipal Mechanical and Electrical Industry Office,apply for the temporary measure of "release first,inspection later",and coordinate with the customs inspection department to arrange physical inspection priority.
• Second Step: Contact the overseas supplier,and get the original factory certification and local maintenance records in Germany supplemented within 24 hours,to prove the rationality of the equipment depreciation.
• Third Step: Draft a detailed statement of explanation,to inform the customs that the equipment is custom-made for specific models,and its fair market value is indeed lower than that of general-purpose models.

Finally,we obtained the tax payment notice on the last day of the bank’s payment deadline,completed the tax payment and got the goods released.Manager Lu later told me that if there was no professional agency involved,he would not only lose the batch of goods,but also face huge compensation claims from the German supplier.This case fully proves that under the CAD model,a professional customs broker is not just a service provider running errands,but also your risk firewall.

Practical Operation Suggestions for CAD Import in 2026

Based on Zhongshitong’s experience across national ports and the global agency network,I have the following very pragmatic suggestions for enterprises planning to adopt the CAD model for import:

First of all,it is mandatory to specify "customs clearance exemption clauses" in the trade contract.The contract should stipulate that customs clearance delays or extra expenses caused by destination country laws and regulations (such as safety access,environmental protection standards) shall be borne by the buyer or resolved through mutual negotiation,to avoid payment breach risk caused by customs inspection.

Secondly,make full use of the policy dividend of "declaration at local customs,and inspection and release at the port of arrival".If your enterprise is not located in Shanghai but in the Yangtze River Delta region,you can take advantage of the cross-district declaration policy.In 2026,we have achieved integrated customs clearance across the Yangtze River Delta customs zones,where data sharing is smoother.You can complete document pre-entry at the local customs in advance,so that the goods can be released quickly upon arrival at the port,greatly shortening the customs clearance time and winning precious document retirement period for CAD operations.

Finally,attach great importance to the collaboration between "paperless customs declaration" and "electronic payment".The current China International Trade Single Window system already supports multiple guarantee methods including tariff guarantee and aggregate tax collection.For high-value CAD businesses,it is recommended to apply for a tariff guarantee in advance,so that the goods can be picked up first during the customs valuation period,without waiting for the completion of the valuation procedure to get the goods released,completely solving the time deadlock under the CAD model.

Import customs declaration is far more than simply filling out forms,especially for CAD operations,which require precise scheduling of capital chain,information flow and goods flow.With Shanghai headquarters radiating to the whole world,Zhongshitong has rich experience in handling various complicated scenarios,and we know best how to help you make every penny count and keep all risks outside the national border under the premise of full compliance.