Compliance Operation Guide for Import-Export Agency Cash on Delivery (COD)
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Compliance Operation Guide for Import-Export Agency Cash on Delivery (COD)
Against the backdrop of global supply chain restructuring in 2026,more and more overseas buyers are requesting COD (Cash on Delivery) for importing Chinese goods,while export enterprises need agents to ensure safe foreign exchange receipt after goods arrive at the port.As a foreign trade agency deeply rooted in Shanghai Port for 20 years,I’ve seen too many enterprises fall into the dilemma of "goods arrived but payment hard to collect" due to insufficient control over COD risk details.

1.Destination Port Certification: Advance Verification to Avoid "Payment Delay" Risk
Mandatory certification requirements for imported goods vary by country and directly impact COD settlement timeliness.For example,in 2026,the US FDA added a new "Bisphenol A (BPA) Migration Detection" standard for food contact materials,and the EU introduced "CE-RED Directive" electromagnetic compatibility certification for electronic devices.I once assisted a Shenzhen electronics company in exporting smart home products to the US.The agency team discovered in advance that the products failed the FDA BPA test,prompting timely rectification and avoiding 14-day detention at the Port of Los Angeles,which would have caused the buyer to refuse payment of the balance due to delay.
Zhongshitong’s core action is "three-document pre-verification":
- Destination port customs supervision list (e.g.US FDA 21 CFR 177.1520)
- Importer qualification documents (e.g.EU CE certification holder information)
- Product compliance certificates (e.g.ISO 9001 quality system certification)
For RCEP member countries,applying for Form R certificate of origin can increase tariff reduction from 5%-15% to 10%-20%,directly reducing buyer refusal probability.
2.Anti-Dumping Early Warning: Key Product Risk List for 2026
| Commodity Category | Target Country | 2026 Anti-Dumping Duty | Zhongshitong’s Countermeasure |
|---|---|---|---|
| Aluminum Bathroom Hardware | US | 19.8%-25.6% | Apply for low tax rate with "Non-originating component ratio ≤5%" |
| Stainless Steel Tableware | EU | 12.5%-16.3% | Adjust HS code to 961290 (classified as "Kitchen Utensils") |
| Photovoltaic Modules | Southeast Asia (Vietnam) | Temporary anti-dumping duty 4.5% | Add "Assembled in China" to certificate of origin to avoid origin disputes |
Special Reminder: In 2026,disputes over "Non-Market Economy Country" designation have increased.Enterprises must clearly indicate "Production Process" (e.g."All processes completed in China") in customs declaration "declaration elements" to prevent destination country customs from applying non-market economy tax rates.

3.Export Tax Rebate Optimization: Document Closed-Loop Management under COD
In COD model,export tax rebate is directly linked to foreign exchange receipt progress.A Jiangsu chemical enterprise once had its VAT invoice "goods name" differ from customs declaration "product name" ("Chloroprene Rubber" vs "Synthetic Rubber"),leading to tax rebate rejection and a 3.2 million yuan loss.
Zhongshitong’s standardized process:
- Pre-examination: Three-dimensional comparison of "product name-specification-unit" across customs declaration,VAT invoice,and export invoice
- Adjustment: For sensitive categories (e.g.chemicals),add "CAS number" (Chemical Abstracts Service registration number) to "declaration elements" in advance
- Declaration: Use "Export Tax Rebate Pre-declaration System" for real-time customs data verification,ensuring tax rebate within 90 days
The 2026 policy requires export tax rebate declarations to match foreign exchange management system data.Agents must provide cross-verification reports of "export foreign exchange receipt verification form" and "bank receipt".
4.Foreign Exchange Receipt Safety: Dual Hedging of Exchange Rates and Demurrage
COD’s core risks include exchange rate fluctuations and hidden costs.A Shanghai machinery enterprise exporting machine tools to Brazil suffered 12% foreign exchange loss due to real depreciation after failing to lock in exchange rates in advance.Zhongshitong’s solutions:
- Exchange rate management: Use "forward settlement + batch settlement" strategy.In 2026,USD/BRL fluctuates 5.1-5.9; lock 5.5 mid-rate to reduce losses
- Document review: Double-check bill of lading,packing list,and commercial invoice for consistency in "shipping mark-gross weight-container number" to avoid 12,000 USD average demurrage per bill (2026 data)
For high-risk countries (India,Turkey),include "demurrage borne by responsible party" in agency agreements.Zhongshitong’s global network provides "24-hour double review report upon arrival" to reduce disputes.
Final Summary: In COD model,import-export agency value extends beyond "collection/payment" to full-chain risk control over destination country policies,customs supervision,and exchange rates.Leveraging Shanghai Port’s "one-stop customs clearance" and 200+ country agency network,Zhongshitong helps enterprises achieve "smooth goods flow and safe fund collection" in complex trade environments.
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