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 .

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

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.