C.i. Process China consulting

China Customs expertise and logistics advisory services

By C.i. Process Shanghai
[ Customs & logistics ]
The badge from the China customs

The General Administration of China Customs (GACC) located in Beijing is the national headquarters of Chinese customs. It supervises all the customs administrations of the country and reports directly to the State Council. Composed of 18 departments, 8 entities and institutions directly affiliated with Beijing, it also supervises the official associations (Customs Institute, Association of Customs Brokers, the Port Society of China, the Association of Free Trade Zones and Processing Zones for re-export). The Central Commission has setup an internal disciplinary inspection office.

the Chinese Customs are member of the World Customs Organization (WCO) since 1983.

China customs consulting page
  Publication updated on June 24, 2024      
| table of content and links to each section |

1. Chinese customs overview, figures and statistics

Restructured in 2018, the Chinese customs have 47 direct branches.

They are the provincial administrations in charge of regional customs offices, 2 supervision offices in Tianjin and Shanghai, 42 customs districts as well as 2 training centers.

678 customs offices are assigned to processing import & export formalities and employ 100,000 Chinese customs officers, including an anti-smuggling customs police authority.


A Customs office in Shanghai (Baoshan District)

  • the Customs collect duties and taxes, import VAT, consumption tax and tonnage taxes on cargo ships. A recent activity report shows the annual collection of more than 1.5 trillion RMB (CNY), increasing from 1.5% to 2% per year.

  • Since 2010, the Chinese Customs also declare the average import tariff level has been adjusted to below 10% against more than 15% before China's accession to the WTO (December 2001). in 2023, it is said to reach 7.3% in average.


2. Key particularities of the Chinese Customs

a. A customs rating system for import export companies

China registration certificate

Any international trade company established in China must register with an Office of International Trade Operators.

Then, distinctly register with the supervisory Chinese Customs Office. Customs assigns them a rating that reflects their status, scope and declarative behavior.

The rating applies to all Chinese-invested enterprises, 100% foreign invested subsidiaries (WOFE) and joint ventures. The treatment and efficiency of the customs services differs according to the rating.

b. An importer or exporter must be authorized and may face restrictions

special installation licence in China

Companies established in China
have a business scope shown on their Business License.

The business scope defines a perimeter of authorized activities (import export only or assembly, assembly or industrial production) which concerns one or more families of the products mentioned.

Thus, a company which has been granted the import rights for cosmetic products, for example, could not freely import electrical equipment or machines.

International trading companies that export from China may be required, depending on the nature of their products, to request additional licenses, special permits or quotas.

Importers or manufacturing companies may also need to obtain special permits.

The certificate on the left is an example of an additional special permit that must be obtained by any company that sells and installs elevators in China.

c. The situation of customs inspections with contradictory conclusions

  • A company that imports products in several Chinese entry ports may be inspected at the same time by several different customs offices. The possible zeal of officers in the Inspection Department can lead to conclusions diametrically opposed to those of their colleagues in other regions. In these cases, some (long) contradictory procedures will have to be initiated because the preliminary conclusions of customs inspections have no binding force at the national level.

  • Not all Chinese customs offices allow official classification of products according to their Chinese tariff heading or HS (customs) codes. In Europe, this is called a BTI (binding tariff information). This can be problematic to apply uniform customs clearance procedures at multiple entry points in China. Current regulations allow the Customs to retroactively sanction customs declarations. Depending on their findings severity, the retroactivity timing can range from 3 to 10 years.

  • Litigation files are transferred to a dedicated "Customs anti-smuggling department". It has police powers.

d. Chinese customs classification and tariff codes different from European HS codes

  • China adopted the 10 digits HS code system in 1992. Since 2018, the Chinese HS code system has migrated to 13 digits codes. These 3 digits extensions are specifically used for the inspection and quarantine services.

    Although the terminology HS (Harmonized System) suggests a similarity of customs codes in the world, the tariff classification and customs codes adopted by China often differ, from its first 8 digits, from the European customs codes of the Integrated Tariff of the European Union for example.

  • A well informed importer or exporter will mind to conduct the relevant customs codes preliminary check. this, both for declarative and tax considerations than to ensure the import regulations and cargo release conditions into the Chinese market.

China import declaration at the Customs
Example (header) of import declaration submitted to the Chinese customs

e. Composition and calculation of import duties and taxes in China

  • Determination of customs value : the latest regulation in force is since December 2013. It confirms that Chinese customs officials determine the value based on the transaction level of similar products imported into China at the same time as the goods to be assessed. As in all other countries, customs officials reserve the right to re-evaluate the value of import declarations that they find suspicious.

  • The duties and taxes to be paid when importing into China consist of :

    • customs duties
    • VAT (value added tax) or GST at a variable rate depending on the nature of the goods
    • a consumption tax on certain products (equivalent to excise duties in western countries)

  • Depending on the country of origin of the imported goods, the applicable customs duty rates are not the same. Overall, a distinction is made between general rates (without customs agreement) and preferential MFN rates (most favored nation agreements). Then there are interim rates (preferential or punitive) and preferential rates applicable to so-called least developed countries. The percentage of import duties in China therefore varies according to the agreements in force with certain countries or regions. For example, in November 2020, China signed a free trade agreement called RCEP with a group of 15 countries, including 10 from ASEAN. Since 2021, specific tariffs are applicable to goods produced within RCEP member countries. They are lower to MFN rates.

  • Below is a practical example applicable in 2024. It show a wide range of customs duties rates levied in China depending on the customs origin for a bottle of grape wine.

    Fresh grape wine in a container of 2 liters or less
    European Customs HS Code
    (the first 8 digits out of 10)
    Chinese customs HS code
    (according to the China nomenclature)
    China import General rate
    180 %
    (rate applicable if no customs agreement)
    MFN (most favored nation) rate
    14 %
    (applicable to Europe for example)
    Current 2024 rate for a USA origin
    from 29% to 54%
    (temporary trade war retaliatory measures)

    Conventional (bilateral) rate negotiated with certain countries or regions

    11.2 %
    Pakistan origin
    13,1 %
    0 %
    Switzerland, Costa Rica, Island, Peru, Hongkong, Mauritius island, ASEAN countries, Georgia, Chili, Macao.
    Ratee applicable to countries members of RCEP (Regional Comprehensive Economic Partnership)
    10,2 %
    from 0 to 9,8 %
    South Korea
    0 %
    Brunei, Myanmar, Cambodia, Indonesia, Laos, Malaysia, Philippines, Singapore,  Thaïland, Vietnam, Australia, New-Zealand.
    + consumption (excise) tax
    + 10 %
    (applicable on ordinary wine)
    + value added tax (VAT)
    + 13 %
    (ordinary rate of 13% applies)

      • Calculation formula for China import duty : duty rate x CIF value to the Chinese port
      • Calculation of the excise tax : [(CIF value + import duties) / (1–10%)] x 10%
      • VAT calculation base = (CIF value + customs duty + excise tax) x VAT rate.

f. Denouncement is encouraged and paid for by the Chinese authorities

  • In their continued fight against corruption, the authorities have largely involved consumers in these measures. They encourage denunciation with dedicated hotlines phone number made available to complainants.

  • These provisions affect first of all aspects of current consumption (counterfeits, forged products, expired consumption date, etc). They also have a strong impact on import export operators. A complaint or denunciation file often comes from a competitor, a customer, or a unhappy employee. Whether justified or not, the denunciations remain a problem that leads to dedicated inspections. The control offices, including those of the Chinese Customs, have the obligation to send conclusions in writing to the complainant.

  • Apart from administrative and criminal sanctions (fines, penalties and directors' liability), it is the company's reputation that is damaged in China. Thus, administrative convictions, fines and past offenses are listed in the public registry of official information.

  • The Chinese social credit system (社会 信用 体系) initiated in 2014 aims to assess and regulate not only the individuals behavior but also the companies reputation.

g. Chinese standards and formalities for product qualification and approval

  • As a non-tariff barrier tool that is developing as China has become a key player in international trade, the authorities have developed a specific system of standards and certification. Throughout China, port and airport Customs offices are one of the import checkpoints.

  • The CNCA (China and Accreditation Administration) controls the system of Chinese standards GB (Guo biao standing for national standard). They constitute the only standard of normative tests to be conducted to certify a product sold in China. Without a GB standard, a CCC (China Compulsory Certification) certificate is not required. On the other hand, the Chinese customs do not recognize an American or European Certificate of Approval. They do not recognize either a test report, certificate and compliance markings associated with the UL, GS, or NF standards for example.

  • China sale approvals are also required for food products, cosmetics, pharmaceutical products and medical devices. Qualification and checks are conducted by the NMPA and the CFDA, the 2 administrations dedicated to health products safety in China.

3. Special customs procedures for trade with China

In addition of from the regular import procedure subject to customs duties and taxes, there are 3 special customs regimes. They are the temporary admission, warehousing, inward processing trade and outward processing trade regimes. All may suspend the tax and duties payment.

a. The temporary admission regime

It is intended for a temporary importation of goods that will be re-exported as is, without processing or modification. Their use is therefore predefined. The most frequent situation concerns products presented during a trade fair or exhibition.

le carnet ATA en Chine et régime d'admission temporaire


Organizers of international trade shows in China have special agreements with dedicated logistics providers, often imposed on participating exhibitors.

Some show organizers allow exhibits to be sold, consumed or destroyed on site. In this case, customs regulations will of course change.

Other trade fairs are organized in such a way that products must leave Chinese territory after the exhibition.

Since the late 90s, China has accepted ATA carnets for temporary exports, for use at trade fairs and exhibitions only.

Since January 2019, Chinese customs have accepted ATA carnets for trade samples and professional equipment.

However, prior declaratory procedures must be well prepared in advance, as simply presenting the carnet on arrival will not be enough.




b. The customs (bonded) warehousing regime

The bonded warehousing regime allows for the storage of unprocessed goods pending their assignment. Thus, they can either be imported into China (definitive import regime) or re-exported from China. For some situations, China's 21 Free Trade Zones (FTZ) present a convenient option of a logistics base. Compare with other types of zones. .

c. The regime of outward processing trade

It allows the export of a product to be processed in China for modification, repair or upgrade before being shipped back. Depending on the status of the consignee who will conduct the modification in China, duties and taxes may or may not be levied by the Chinese authorities. It is recommended to check this aspect carefully. On this kind of subject, the customs will approve only on a case by case basis any application files. China has its own regulations, different from the ones in USA and Europe. It means the customs officers do not handle a processing trade status with the same logic.

Outward processing trade in China refers to a specific kind of trading activity where a domestic company import raw materials or intermediate inputs, process them locally, and then export the finished goods. These exported items are not intended for domestic use or consumption within China. This type of trade is distinct from general trade and bonded warehouse business. The key advantage it may offer is the companies involved may benefit from an exemption or suspension of customs duties and import taxes. This apply on imported raw or auxiliary materials, parts and packaging.

Still, to enjoy the benefits and savings of these preferential measures, the Chinese service supplier shall seek a specific approval from the local authorities (including but not limited to the Customs). Among the items to check carefully, the exact nature of the processing, the customs registration status, the import and export documentation. The contract terms (ownership) between the exporter and the Chinese sub-contractor matters too. At this point, the choice of the incoterm matters too. The possibility to enjoy the benefits and savings of an outward processing trade is not necessarily restricted so some production areas such as a Free Trade Zone (FTZ) or an Export Processing Zones (EPZ).

To save costs on the reduced (or zero) tariffs, the enterprise shall prepare a handbook and get approved first. The handbook keep records of the imported materials, finished goods to be produced and the actual consumption ratio. An accurate method of working is crucial so as to comply with the China importation rules.

Then, all supporting evidence are provided to the customs for verification :

  1. Check the imported materials and components or parts match the imported quantities (contracts).
  2. Verify the declared losses during production or modification are considered acceptable.
  3. Confirm the processed goods quantity aligns with the related importation.

If the declaration is compliant, the import customs duties and tax (VAT or GST) may be waived or refunded. Last, please note all the operations shall be completed within a given pre-approved deadline.

Before engaging in such a trade pattern, it is advised to conduct first a professional in-depth check on the current regulatory and approval conditions. The authorities would give approval only on a case by case basis only.


d. The regime of inward processing trade

Inward processing from China is intended to import products from China, process them in a foreign country and re-export them to China. The processing consists of a modification of the good for assembly, repair, upgrade of components. This type of trade operation is possible between China and the rest of the world. Its principal benefit are exemption of duties / tax upon re-importation in China. However, this type of project deserves a good preparation and follow-up with the customs authorities of both countries. The declared values and transfer price, added value breakdown, et are key matters for tax optimization.


4. Export food and registration at the Chinese Customs (GACC)

On April 12, 2021, the Customs Administration published 2 decrees that come into force starting Jan 1, 2022.

a. decree GACC 248 is the "Regulation on Registration and Administration of Foreign Producers of Food Imported to China" (GACC Decree 248). It requires that foreign food manufacturers and storage sites that export to China must register with the Chinese customs. The decree also stipulates that food products are divided into two categories.

b. decree GACC 249 is the “Administrative Measures on Food Security in Import and Export of China” (Decree 249). It covers a wide range of requirements for exporting food products to China. It includes the registration of overseas production manufacturers, the processing records traceability by importers and exporters, quarantine & inspection matters and food labeling guidelines.


For more details on the products classes and procedures, you may refer to our page dedicated to the formalities for foodstuffs registration with Chinese customs (GACC).


China's exports to the rest of the world are tightly controlled

  • Except in special cases, a regular shipment from Europe or USA is not subject to a strong customs control when being exported. In China, fairly heavy export customs clearance procedures exist for almost all shipments. The procedures to export may be as demanding and time consuming as they are for importation. Why?

    • First because the export value of each shipment from China is subject to a VAT (tax) refund to the exporter. This refund is a part of the VAT paid on domestic purchases and services contracted during the assembly. In past years, there have been many abuses in the declaration of exported value.

    • Also, the authorities wish, from China, to address the problem of fake and counterfeits products. this issue tarnishes its international reputation. The Chinese government signed cooperation agreements with the Customs of many countries so as to take an active part in control campaigns. This practice aims to detect and stop fraudulent, counterfeit or non-compliant products with the essential safety rules of the destination country.

    • From the point of view of European regulations, the year 2023 brings new restrictions on imports from China. For example, a complaint was lodged with the European Commission in March, followed by the implementation of temporary anti-dumping duties that surcharge imports of certain plastics (PET). Concerned about their competitiveness, some PET manufacturers based in China have negotiated additional duties ranging from +6 to +15%. For the others, the general temporary rate is currently set at +24%.

    • Another example of compliance with EU regulations on trade restrictions with Russia. Last September, the Customs sent a note to european operators prohibiting the import of certain iron, cast-iron or steel products containing steelmaking inputs originating in or coming from Russia. This provision indirectly concerns Chinese suppliers who may incorporate components of Russian origin in their production.

    • Herebelow is the header of an export clearance notice issued by Chinese customs.
      export clearance notice issued by the chinese customs


6. What to do when you have a parcel or sample blocked at customs?

  • As an answer to a frequent asked question received from individuals

    • Chinese Customs do not provide any tracking service for your blocked parcels. They also cannot receive information, request or documents directly from you.

    • Typical situation example : you have returned a product to China for reimbursement or replacement. The package is stopped at Customs. A document is missing (invoice, description, indication of value) or the package is damaged upon arrival. Only the consignee in China of the returned package can contact the domestic office or agent of the express courier company you used (UPS, TNT, DHL, Fedex, etc). This agent only may contact the Chinese Customs, if necessary. Also note the China Post and affiliated quick delivery services EMS (Express Mail Service) or SF-Express are agents of many overseas Post Offices.

    • Before returning a parcel from your country to a seller in China, make sure you have oberved all the necessary shipping instructions. This applies for the markings, labeling as well as for the packaging quality if a product value refund or an item replacement is involved.

    • Another example: You send a gift by post to an individual residing in China. What to do if the parcel sent to China is blocked on arrival at customs? Often China Post calls the recipient to let them know that a package is blocked. Otherwise, try to locate the parcel by entering its number in the China Post tracking system. If necessary, the receiver can go, provided with his ID card or passport, in a post office of the place of destination to obtain information and assistance. Note that a package may be confiscated by the Customs if it contains items that are regulated or prohibited for import. Finally, consider that the importation of personal items authorized in China can be expensive as subject to tax rates ranging from 15% to 60%. The mention "gift without commercial value" will not be enough to bring its customs value to zero.

  • For companies that send samples to Chinese supplier or customer

    • Be careful with "sample" shipments even if they show "no commercial value". There is a lot of abuse of this process for products that are not actually samples. The Chinese Customs can stop, return or destroy the package if its content do not meet the required standards. The Customs also reserves the right to collect customs duties + VAT, according to a value and tax reckoning base of their choice.

      It is advised to check with your supplier or prospect in China for specific declaration statements and other points of attention before sending or returning a product to them.

    • Beware, of course, of under-declarations of value or fraudulent declarations of contents designed to avoid charges and taxes on arrival, or to circumvent a need for certification or compliance on arrival. Good understanding and coordination with the importer in China is essential to the smooth running of the declaration and import procedures. This starts with verifying that the consignee and importer named on the shipping documents has the correct licenses and authorizations. Fraud is as common as it is severely punished.

    • It should be remembered that the entry in China of products intended to be exhibited at trade fairs or shows has a different customs status depending on whether the goods are to be returned to the exporter or purchased or consumed locally.

7. Customs news, lower import duties and retaliatory tariffs in 2024

  • To an extent applicable since January 1, 2024, the Customs Tariff Committee of China's State Council decided to adjust its tariff schedule for 2024 and expand the number of tariff items. Starting this year, China is imposing provisional import duty rates on 1,010 items, the rates of which are lower than the MFN duties. These products can be classified into the following categories:

    To improve public health and ease the financial burden on patients, customs duties are being removed from anti-cancer drugs. In particular those used for malignant liver tumors, as well as on drugs and raw materials intended for rare diseases, such as those treating pulmonary hypertension. Customs duties are also reduced on certain food preparations intended for specific medical purposes.

    To encourage innovation in the high-tech manufacturing industry, a reduction in duties is applied to strategic equipment and components. Including the gas diffusion layers of fuel cells, biogas-powered generators with internal combustion piston engines.

    Customs duties are also reduced on sweet corn, coriander and burdock seeds.

  • In 2024, China will also increase import customs duties on other products. This measure aims to regulate supply and demand in the domestic market and modernize its industries. Among the adjustments, and in accordance with commitments made by China to the WTO, is the increase in duties on ethylene and propylene substrates and certain liquid crystal glass.

  • Preferential customs duties are maintained for 43 least developed countries with diplomatic relations with China. The objective is to support their development.

  • China has revised its customs law to strengthen its commercial defense mechanisms. Adopted on April 26 by the Chinese National Assembly, the new legislation will take effect on December 1st. It includes specific rules regarding taxes on imports and exports, as well as tax incentives. It also allows China to take retaliatory measures against countries that do not comply with trade agreements. Article 17 of this revision introduces a principle of reciprocity for markets with which China has preferential trade agreements, allowing the imposition of equivalent customs duties if these countries do not honor their agreements. While similar provisions already existed in the 2004 foreign trade law, this update provides China with a new deterrent tool amid increasing trade tensions.

  • Overall, these tariff changes in 2024 illustrate China's commitment to protecting its production and supply chain. These customs adjustments aim to allocate resources favoring technological innovation, modernization of industries and sustainable development. In addition, they mean to strengthen the country's role in the reconfiguration of the global industrial network and in its increasing integration into the international free trade network.

  • As a reminder, the Commission in charge had, since 2022, taken the following decisions:

    • Reduce or eliminate import duties on nearly 1,000 products : ski equipment (editor's note : Winter Olympic Games in Beijing), paintings older than 100 years old, fuel-efficient auto parts, cancer drugs, some mineral raw materials, industrial components promoting environmental protection, etc. A further reduction of duties is also expected on high-tech products.

    • Increasing import and export duties from China for certain products (including gelatin, pork, amino acids) or raw materials (including phosphorus, copper).

  • The Commission indicates that these measures are intended to balance the conditions of supply of resources and goods imported and manufactured locally. They are also intended to contribute to the efficiency of Chinese industrial production as a whole.

  • Like the regular updates of new business fields regulations, this tariff adjustment policy illustrates the Chinese authorities' continuous attention to trade balance.

  • Under the Regional Comprehensive Economic Partnership (RCEP) signed in April 2020 between 15 ASEAN countries, China is also reducing tariffs on a large number of goods from 9 RCEP countries. These countries are Australia, New Zealand, Japan, Singapore, Brunei, Cambodia, Laos, Thailand and Vietnam. With this measure, over 90% of traded goods should be exempt from customs duties. The Commission specifies that it will announce at a later date the timetable for the implementation of tariff cuts on imports from other RCEP member countries. These are Indonesia, Malaysia, Myanmar, the Philippines and South Korea. This also means that western companies exporting to RCEP member countries should be vigilant about the competitiveness of their products.

  • On the other hand, with the ongoing situation of trade war relations between the US and China, reciprocal measures to maintain or increase tariffs continue to evolve. On the US side, 3 consecutive rounds of punitive tariffs have been introduced since early 2018, starting with steel and aluminum. They represent $350 billion in annual imports from China. In return, the Chinese giant is imposing so-called retaliatory tariffs on evolving categories of products. They come in addition to the regular customs duties normally applicable. Chinese punitive tariffs range from +5% to +25%. This changing context is accompanied by frequent announcements of exemptions (or extensions) of these tariffs. They fluctuate upon the progress of high-level negotiations between the United States of America and China.

8. Our expertise in China Customs and logistics advisory consulting services

  • Benchmarking of transport services providers (air, sea, rail, road) on logistics and warehousing projects, freight forwarders monitoring and calls for bid.

  • Optimization of costs and logistics process : implementation of import and export customs clearance procedures, inward and outward processing trade files, optimization of import export flows, LCL/LCL, LCL/FCL grouping consolidation. Consulting and Standard Operating Procedures (SOP) service for Customs declaration formalities.

  • Advice and preparation of specific projects and temporary imports : regulations and practice of ATA carnets in China, imports for processing and re-export.

  • Cross-border eCommerce : comparison of Chinese cross-border import solutions for B2C export sales of exported products sold to the Chinese customers.

  • Preparation of health compliance files for foodstuffs as well as for pharmaceuticals, drugs, skin care products and medical apparatus. Watch service on the Chinese market.

  • Standards, Certificate of Approval and certification in China : preparatory files for CCC conformity marking and compared solutions from authorized laboratories.

  • Export to China of machinery and industrial equipment : these files deserve special attention. We take care of the preparation of the import file with the Customs so as to ease the import process by your China subsidiary or agent.

  • Implementation of storage, delivery and distribution solutions by product category. Dry items, temperature-controlled or regulated products.

  • Projects negotiation and assistance during disputes with the chinese administrations (Customs office, AQSIQ, CIQ, CFDA, port authorities, Free Trade Zones (FTZ), bonded logistics zones).

  • Customs regulatory watch & advisory : laws and regulations, Chinese HS codes classification, negotiation and assistance during inspections.

  • Import files advice and follow-up. Qualification and manufacturing SOP for dangerous or chemical products.

  • Consultant in managing the logistics function within the scope of a larger sourcing project, qualification or relocation of Chinese suppliers and distributors.

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Our experience in administrative, registration and licensing matters in China
A managing resident for 30 years in the Chinese world
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An extensive knowledge of business practices and cultural codes
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