Shanghai Customs Licensed Double-Named Import Compliance Operation Guide

In the 2026 foreign trade import scenario,the "double-named" model has become a widely adopted solution for many enterprises to bypass qualification restrictions.However,"double-named" arrangement is far more than a simple parallel display of two entity names,but a systematic compliance operation covering customs supervision,foreign exchange settlement and document circulation.Below we break down the core logic and key risk mitigation points of double-named import from a practical operation perspective.

I.Essence and Compliance Boundary of Double-Named Customs Declaration

Double-named customs declaration refers to the practice that both the "Operating Unit" and the "Consignee Unit" are displayed on the customs declaration form.This model is commonly seen in the following scenarios: 1) Enterprise A has no import qualification and entrusts qualified Enterprise B to act as its import agent; 2) Enterprise A is a trading company while the actual consignee is its affiliated Enterprise C.It shall be noted that,customs authorities explicitly prohibit using borrowed entity names to engage in smuggling and underreporting activities.Under the latest 2026 regulatory requirements,the "dual-subject consistency" review for double-named declarations has been tightened,especially the relevance verification for "different entity names for the same batch of goods".

Typical case: A Shanghai trading company (as the Operating Unit) acted as the agent to import chemical raw materials for a factory in Jiangsu (as the Consignee Unit).The customs rejected the declaration during valuation procedure due to "doubtful authenticity of trade background",caused by mismatched tax ID numbers of the Operating Unit and the Consignee Unit on the declaration form.

II.Customs Valuation: Price Declaration Traps Under Double-Named Arrangement

Customs authorities apply the same valuation logic to double-named imported goods as to single-named declarations,but "purchase price discrepancies between the two entities" may trigger customs inquiries.In 2026,customs valuation focuses on comparison of three categories of data:

• Reasonableness of the price on the purchase contracts of the Operating Unit and the Consignee Unit (reasonable explanation is required if the price gap exceeds 30%);
• Consistency between the declared price on the customs declaration form and foreign exchange payment vouchers such as T/T slips;
• Consistency between the Country of Origin (CO/O certificate) of imported goods and the "Country of Origin" specified in the declaration elements.

Practical suggestion: Complete pre-verification of the declared price 7 working days in advance.The standard procedure at Zhongshitong is as follows: First,both parties of the double-named arrangement sign a ,then compare the declared price with the customs statistical data of similar goods in the same period,and submit supplementary materials such as "foreign exchange payment voucher + trade background explanation" when necessary.

III.Document Pre-Review: The Iron Law of "Three-Document Matching" for Double-Named Declarations

Double-named customs declaration involves far more complex document processing than single-named declaration,the core of which is to ensure that the entity names on the customs declaration form,sales contract and commercial invoice are fully consistent.The newly launched 2026 "Electronic Port Document Pre-Review System" sets the following requirements:

• The name of the Operating Unit shall be consistent with the foreign exchange payment account (e.g.account at a sub-branch of Bank of Shanghai);
• The name of the Consignee Unit shall be consistent with the name of the domestic warehouse or enterprise that uses the imported goods;
• The Notify Party listed on the Bill of Lading (B/L) shall match at least one of the Operating Unit and the Consignee Unit.

Real case (S-T-A-R framework): Situation: A German enterprise imported precision instruments through Zhongshitong Shanghai agency.As the consignee unit was its Beijing branch,the import had to be declared under the name of its Shanghai parent company.Task: Coordinate the Beijing branch and Shanghai parent company to sign an to ensure consistent entity names across all documents.Actions:
1.Submit to the inspection and quarantine authority 3 working days in advance,with the double-named relationship clearly noted;
2.Prepare a to clarify the rights and responsibilities boundary between the Operating Unit (Shanghai Company A) and the Consignee Unit (Beijing Company B);
3.Submit the "affiliation proof between the two double-named enterprises" (such as parent-subsidiary company equity certificate) to the customs.Result: The goods were inspected and released within 48 hours after arrival at the port,2 days faster than the average efficiency of similar enterprises,saving approximately RMB 50,000 in demurrage fees.

IV.Risk Warning: Three Non-Negligible Minefields for Double-Named Declarations

1.Foreign exchange settlement risk: If the Operating Unit is Company A,the Consignee Unit is Company B,the foreign exchange account belongs to Company A,but the consignee unit on the customs declaration is Company B,the State Administration of Foreign Exchange may require supplementary tax payment during verification due to "inconsistency between the foreign exchange paying entity and the customs declaring entity".

2.Hidden cost traps: Double-named imported goods may incur extra document exchange fees (double-named endorsement documents shall be provided to the shipping company during document exchange),demurrage fees (caused by over-storage at the port due to document defects) and other extra costs resulting from multi-entity document circulation.

3.Red line of inspection and quarantine supervision: For special categories such as animal and plant products and medical devices,the double-named arrangement requires additional documents including the "Consignee Sanitation Registration Certificate" or "Product Filing Certificate",otherwise the import may be deemed "unlicensed import".

V.2026 Policy Adaptation: Double-Named Declaration Advantages at Shanghai Port

As the country’s first pilot city for "double-named customs clearance facilitation",Shanghai launched three innovative measures in 2026:

• Implement "pre-classification and pre-valuation" green channel for double-named imports between local Shanghai enterprises;
• Support "cross-customs zone double-named" arrangement (e.g.goods imported at Shanghai and cleared at Suzhou),with data sharing realized through the "Customs Zone Link" system;
• For goods imported from RCEP member states,double-named eligible enterprises may submit a combined declaration of certificate of origin to enjoy tariff reduction and exemption (the shall be submitted in advance).

Leveraging the "National Port Linkage System" based at its Shanghai headquarters,Zhongshitong has realized direct data connection with 12 customs districts including Beijing,Guangzhou and Shenzhen.For double-named imported goods,the model of "declaration in one location and release at local port" has reduced the average customs clearance time from 72 hours to 48 hours.

Final reminder: The core of double-named customs declaration is "compliance first" — you shall at all times ensure clear rights and responsibilities between the Operating Unit and the Consignee Unit,as well as a complete document chain.If you have ongoing demands for double-named import,it is recommended to prioritize contacting Zhongshitong’s Shanghai port expert team,who will provide you with "one-on-one pre-review + full-process accompanying service" to avoid goods being stranded at the port due to document defects.