On March 26, 2016, China’s General Administration of Customs (GAC) announced a revision of the import and export declaration forms (GAC Announcement, No. 20 of 2016).

The revision has accommodated and consolidated all the legislative changes made by Customs, Ministry of Finance, Ministry of Commerce, and National Reform and Development Commission etc. ever since 2008, which are relevant to, or have impact on, import and export declaration process. Considering the number of fields that have been changed or added, the revision is unprecedented in past decades.

For example, the revision has:

• Adjusted the filling requirements for many fields such as the Contract Number, Declaration Entity, Mode of Transport, Recordation Number, License Number etc.
• Added a number of fields like Country of Origin, Country of Destination, Special Relation, Impact on Transaction Value, Royalty Payment etc.
• Deleted some obsolete fields like Foreign Exchange Permit Number, Customs Remarks and Release Date, Declaration Form Print Date etc.
• Changed some field names to be consistent with relevant laws and regulations, replaced Operating Entity with Consignee/Consignor, replaced Consignee with End-User, and substituted Manufacturer/Seller for Consignor
• Enlarged the item list so that the number of items that can be declared on one form increased from 20 to 50

Behind the tangible changes there are significant implications for trade compliance. Unfortunately, most people fail to recognize the signals and are completely unaware of the things on horizon.

For instance, multinationals have many transactions happening between related parties. I have advised many of them to report the relation to Customs if the import or export transaction is between related parties. This is because it is an obligation by legislation and the relation will have direct impact on Customs valuation.

Well, glad to see that my advice is in line with Customs authorities. Special Relation confirmation has been added as a new field on declaration forms, each and every shipment either inbound or outbound must explicitly tell if it is a transaction between related parties.

Another example is the Country of Origin. China has 14 live Free Trade Agreements and is actively negotiating more with the rest of the world. On the other hand, as China is getting more powerful and confident as a major power, they become apt to use trade remedies such as anti-dumping, countervailing, and safeguard measures more frequently. In either way, origin determination with preferential, or non-preferential, rules of origin is critical. Therefore, businesses need to put more care or attention to their origin declaration with the revised forms.

As we know, the imports and exports should be classified properly and declared together with the HS codes determined by classification process. People like simplicity and tend to consolidate various parts and classify them into one HS code.

For example, an automotive manufacturer tends to classify everything under one HS code as the parts or components of a specific vehicle. Obviously, anyone with basic classification knowledge would see the problems there. The old declaration form could take only 20 items on one page, more than that, additional forms are required. This may become a concern when people want to classify items of one shipment as detailed as possible. To increase the space from 20 items to 50 items, Customs is encouraging businesses to spend more time and efforts on classification, which leads to more detailed and accurate HS codes.

If you do not have a chance to review the revised declaration form and its impact with your logistics and compliance managers, your import and export agents, or your Customs brokers yet, you’d better do it now. Because starting March 30, 2016, all import and export declarations submitted to China Customs must be based on the revised forms

If you or your teams have difficulties in understanding the terms used in the revised forms and their compliance implications, feel free to reach out Tradewin representatives for help.

Also, if you are developing an import and export manual and want to have the latest legislative changes to be reflected in the manual, that is what we are good at! Reach out to us. Let us handle the details.