On June 22, 2021, the General Administration of Customs issued No. 47 of 2021 (Announcement on Copying and Promoting Cross-border E-commerce Enterprise-to-Enterprise Export Supervision Pilot in Customs ), which will come into force on July 1, 2021. The specific content of the announcement is as follows:
To conscientiously implement the nationwide reform of “decentralization, regulation and service”, we will focus on cultivating and stimulating the vitality of market players, the spirit of video and telephone conferences, and further promote the healthy and orderly development of cross-border e-commerce (hereinafter referred to as “cross-border e-commerce”), and help companies to better develop internationally The market, after research, decided to replicate and promote cross-border e-commerce enterprise-to-enterprise (hereinafter referred to as "cross-border e-commerce B2B") export supervision pilot. The relevant matters are hereby announced as follows:On the basis of the existing pilot customs, replicate and promote cross-border e-commerce B2B export supervision pilots in customs across the country. Cross-border e-commerce companies, cross-border e-commerce platform companies, logistics companies, and other domestic companies that participate in cross-border e-commerce B2B export business should file with the local customs in accordance with the relevant regulations of the customs declaration unit. Other related matters shall be implemented in accordance with the Announcement No. 75 and No. 92 of the General Administration of Customs of 2020. If the contents of the General Administration of Customs Announcement No. 75 and No. 92 of 2020 are inconsistent with the contents of this announcement, the contents of this announcement shall prevail.
The General Administration of Customs No. 75 (2020) mentioned in the announcement is the "Announcement on the Implementation of Pilot Export Supervision of Cross-border E-commerce Enterprises to Enterprises", which will be implemented on July 1, 2020. The relevant content is:
1) Cross-border e-commerce B2B direct export, customs code "9710":
After a domestic enterprise has reached a transaction with an overseas enterprise through a cross-border e-commerce platform, the goods will be directly exported to the overseas enterprise through cross-border logistics;
2) Cross-border e-commerce export overseas warehouse, customs code "9810":
Domestic enterprises deliver their exported goods to overseas warehouses through cross-border logistics, and then deliver them to buyers from overseas warehouses after the transaction is realized through the cross-border e-commerce platform
3) Cross-border e-commerce B2B exports that transmit relevant electronic data according to customs requirements shall be subject to customs supervision.
4) Pilot customs: 10 customs directly under the jurisdiction of Beijing, Tianjin, Nanjing, Hangzhou, Ningbo, Xiamen, Zhengzhou, Guangzhou, Shenzhen, and Huangpu Customs.
Two months later, at the end of August, the General Administration of Customs issued the “Announcement on Expanding the Pilot Scope of Cross-border E-commerce Enterprises’ Export Supervision and Control” No. 92 of 2020, and expanded the pilot scope to Shanghai, Fuzhou, Qingdao, 12 customs directly under the jurisdiction of Jinan, Wuhan, Changsha, Gongbei, Zhanjiang, Nanning, Chongqing, Chengdu and Xi'an .
Regarding the B2B export model of cross-border e-commerce, the General Administration of Customs will start from the publication of Announcement No. 75 of 20 Years in June 2020, and the Announcement No. 92 of 20 Years of the General Administration of Customs will increase pilot customs in August, and the current release 21 will be one year later. No. 47 of the year, the promotion of cross-border e-commerce B2B exports to the national customs pilot, it is not difficult to see that the General Administration of Customs attaches great importance to this model.
So what are the benefits and characteristics of the "cross-border e-commerce B2B export" model for export trading companies, let us understand below.
1. Definition of cross-border e-commerce B2B export
Cross-border e-commerce B2B export, the full name of "cross-border e-commerce enterprise-to-business export", refers to a form of trade in which domestic enterprises transport goods to overseas enterprises or overseas warehouses through cross-border logistics, and complete transactions through cross-border e-commerce platforms. And according to customs requirements to transmit relevant electronic data.
2. Business model classification: two types
(1) Cross-border e-commerce enterprise-to-enterprise direct export, customs code "9710"
(2) Cross-border e-commerce business-to-business export overseas warehouse, customs code "9810"
3. Qualification requirements for participating companies
(1) Enterprise qualification: general credit and above
(2) Handle enterprise filingCross-border e-commerce companies, cross-border e-commerce platform companies, logistics companies, and other domestic companies that participate in cross-border e-commerce B2B export business shall apply to the local customs for filing in accordance with the relevant regulations of customs declaration units for filing management.(3) Handle the record of export overseas warehouse business modelThe export company should file the export overseas warehouse business model at the customs, and the overseas warehouse should be a VMI warehouse leased by the export company or entrusted by a foreign party to manage it.(4) The filing materials submitted by the enterprise to the customs1. "Cross-border e-commerce export overseas warehouse enterprise registration form", "overseas warehouse information registration form";2. Proof of overseas warehouses (the enterprise shall provide corresponding certification materials in accordance with self-operated overseas warehouses, public overseas warehouses, overseas warehouses on e-commerce platforms, and other types of overseas warehouses);3. Other documents deemed necessary by the customs.
Fourth, the enterprise declaration process
(1) For cross-border e-commerce B2B export goods with a single ticket value exceeding RMB 5,000 or involving certificates, inspections, or taxes, enterprises should go through customs clearance procedures through the H2018 customs clearance management system.
(2) For a single ticket with a value of less than RMB 5,000 (inclusive), and does not involve certification, inspection, or tax, enterprises can go through customs clearance procedures through the H2018 system or the unified cross-border e-commerce export system.
Five, the key points of customs declaration
(1) Customs clearance through H2018 (suitable for exporting goods with a single ticket value exceeding RMB 5,000, or goods involved in certification/inspection/taxation)
1. Electronic information transmission:
Before the 9710 declaration, cross-border e-commerce companies or cross-border e-commerce platform companies complete the transmission of transaction order information to the customs; before the 9810 declaration, cross-border e-commerce companies complete the transmission of specific sales information of overseas warehouses to the customs.
2. Customs declaration
Cross-border e-commerce companies summarize transaction order information and declare customs declarations to the customs.
(2) Customs clearance through the unified version of cross-border e-commerce export (applicable to goods with a single export ticket value of less than RMB 5,000 (inclusive) and no certificate/no inspection/non-tax-related goods)
1. Electronic Information Transmission
Before using the 9710 declaration, cross-border e-commerce companies/logistics companies respectively completed the transmission of transaction orders and logistics information lists to the customs; before using the 9810 declaration, cross-border e-commerce companies completed the transmission of overseas warehouse booking information and logistics information lists to the customs.
2. List declaration
Cross-border e-commerce companies or their agents declare the list to the customs, and there is no need to declare the customs declaration form after the list is declared.
6. Facilitation measures
The customs clearance facilitation measures currently available for cross-border e-commerce B2B export business are as follows:
(1) Informatization of the entire customs declaration process
Enterprises can use "single window" or "Internet + customs" to transmit electronic information lists such as transaction orders and overseas warehouse orders online, and all of them are automatically imported in standard message formats; customs declaration forms and declaration lists can be paperless, Simplified the enterprise declaration procedures.
(2) Newly added convenient declaration channel
For goods with a single ticket value less than RMB 5,000 (inclusive) and not involved in certification/not involved in inspection/not involved in tax, customs can be cleared in the form of declaration list through the unified version of the cross-border e-commerce export system, and the declaration elements are more than customs declaration forms. The 105 items in the list are reduced, and there is no need to summarize the declaration forms after the list is declared; this makes the declaration of small, medium and micro export enterprises more convenient and the cost of customs clearance is further reduced.
(3) Simplified declaration in the comprehensive insurance zone
With reference to the simplified declaration method of cross-border e-commerce retail exports (9610) carried out by the customs in the place where the comprehensive protection zone is located, the 9710 and 9810 model list declarations can be simplified according to the first 6 HS codes.
(4) Logistics and inspection convenience
Cross-border e-commerce B2B export goods can be transshipped according to the type of "cross-border e-commerce", and customs clearance through the H2018 system is also applicable to the integration of national customs clearance. Companies can choose a more efficient and optimal way to transport goods according to their actual conditions, and at the same time can enjoy the convenience of priority inspection.
7. Analysis of the benefits of exporting companies using overseas warehouses
(1) For example, the export products of enterprises often encounter the following problems:
1. If the exported goods are defective and need to be returned to China for repair
2. The exported goods are rejected by overseas customers and need to be returned to domestic occasions
It will be very convenient to adopt the "Cross-border e-commerce export overseas warehouse (9810)" model.
(2) The current normal operation mode:
1. Defects of exported goods need to be returned, mainly in the following 3 ways:
1) Return and exchange of defective products (4600): Applicable to bonded products, but re-export is required
2) Repair of defective products: Apply to the customs for "temporary import and export" (2600), and the company pays a deposit corresponding to the import tariff of the goods; the original product is required to be re-exported within 6 months after the repair.
3) Return of defective products (4561): According to the current customs regulations, whether it is a bonded return or a general trade return, the normal import tariff must be paid (increasing the cost for the enterprise), and at the same time when the return is declared It is also necessary to provide a certificate of defective products issued by an overseas agency recognized by the customs.
2. The exported goods are rejected by overseas customers and need to be returned. Only the return (4561) method can be used. The disadvantages are the same as those described in 3, which will also cause inconvenience and cost increase to the enterprise.
(3) When the 9810 model (cross-border e-commerce export overseas warehouse) model is adopted:
It can solve the above types of confusion of enterprises: when handling the return of exported goods or returning for repair, using the defective goods return (4561) mode, there is no need to pay the import tariff. The legal basis for this model is the No. 44 of 2020 (Announcement on the Comprehensive Promotion of Supervision Measures for the Return of Cross-border E-commerce Export Commodities) issued by the Customs in March 20th; it stipulates:
1. Cross-border e-commerce export companies can apply to the customs for the return of goods in overseas warehouses, the customs code: return goods (4561).
2. Cross-border e-commerce export enterprises should establish a return product process monitoring system, should ensure that the returned product is the original export product, and bear relevant legal responsibilities.
3. Returning companies can apply for return of all or part of the commodities listed in the export declaration form, export declaration list, or outbound goods filing list.
4. Export returned goods can be shipped back individually or in batches, and returned goods should be returned to the country within 1 year from the date of export release.
5. The state prohibits entry of goods that are not allowed to be returned. If the returned goods involve inspection and quarantine, the relevant regulations of the customs shall be implemented.
8. Points of Attention
The points to note for companies adopting the 9810 model (cross-border e-commerce export overseas warehouses) are as follows:
(1) Export declaration by the enterprise:
The consignee can only be a designated overseas warehouse that has been filed with the customs; declare the 9810 list (HS only needs to fill in 6 digits), and there is no need to specify the specific overseas customers and the sales amount; it can be understood as export and transport to the enterprise In the overseas VMI warehouses, the ownership of the goods is still owned by the exporting company, so there is no issue of supervision over foreign exchange receipts and payments by the SAFE.
(2) Within one year of exporting, if the overseas warehouse has not achieved sales or the product is defective and needs to be returned to China, the return declaration can be realized without paying import taxes (duties, value-added tax). The return includes: the return of all or part of the goods; the returned goods can be shipped back individually or in batches.
(3) Formal export declaration declaration: When the overseas warehouse actually sells, collect the sales invoices, and then implement the "9810" formal export declaration.
Of course, the customs requires formal export declaration to be completed within 1 year after the goods are exported.
The cross-border e-commerce export overseas warehouse (9810) model in cross-border e-commerce B2B has solved the practical problems of export companies’ uncertain overseas customers, many but complicated orders, small single order quantity, and different transaction prices. ; It also solves the problem that the export goods of enterprises are often required to return or return for repair due to various reasons; in addition, because the export goods are placed in the enterprise's overseas VMI warehouse, each shipment is not restricted by a fixed order, and can be shipped with a full load. , To achieve the effect of reducing international transportation costs.
The author believes that cross-border e-commerce B2B export models (especially overseas warehouses (9810)) will gradually become one of the mainstreams for Chinese companies to develop global trade in the future; customs officials should conduct in-depth research and understanding.