China — Import Procedures & Duties

The General Administration of Customs of the People's Republic of China (GACC / 海关总署) remains the chief authority for import and export control at China's borders, charged with enforcing customs law and collecting tariffs and import duties. Effective December 1, 2024, the statutory framework for customs administration and tariffs is anchored in the Customs Law of the People's Republic of China (as amended November 4, 2017, and still current for customs supervision mandates) and the new Tariff Law of the People's Republic of China, promulgated April 26, 2024, and effective December 1, 2024. The Tariff Law replaces the former Regulations on Import and Export Duties, elevating tariff regulation from administrative regulation to full statutory authority, and aligning with World Trade Organization (WTO) and international practice.

Statutory and regulatory mandate.

• The Customs Law (Arts. 2–5) defines GACC as the body responsible for border control: supervising all persons, goods, means of transport, and articles entering or exiting the customs territory; collecting duties; preventing and investigating smuggling; maintaining customs statistics; and managing other related operations in accordance with statutes and administrative measures.
• The Tariff Law (Arts. 4–11) prescribes the authority and basic rules for tariff imposition, collection, enforcement, exemption, adjustments, and dispute procedures. It sets out the circumstances under which tariffs are to be levied on imported and exported goods and articles, details the scope of tariff payers, and outlines special measures (including retaliatory and provisional duties) under international law or China's trade agreements. The Tariff Law grants GACC the primary authority to collect, adjust, and enforce tariff obligations as a matter of national law, not merely regulation.

Organizational structure. Article 3 of the Customs Law authorizes the State Council to establish GACC as the unified administrator of all customs offices nationwide. Branch customs offices operate only pursuant to national customs structure and regional needs, reporting up to GACC—not to provincial or local governments.

2024 update—legal hierarchy and institutional powers. The 2024 Tariff Law represents a material shift in legal hierarchy, superseding prior regulations with full statutory force, formalizing procedures for duty imposition and adjustments, and incorporating provisions to ensure compliance with both domestic priorities and China's WTO obligations. GACC and its subordinate customs houses remain the exclusive authority for enforcement, registration, and anti-smuggling (Customs Law Arts. 4–5).

Scope of supervision and enforcement powers. GACC's enforcement authority under both the Customs Law and the new Tariff Law encompasses: inspection, seizure, detention, and enforcement actions in connection with violations of tariff or customs statutes. Operational detail—including procedures, rights of review, and penalty provisions—are specified in further GACC measures and implementing regulations (2024 and later).

Transitional note. As of December 1, 2024, references in secondary sources to the pre-2024 "Regulations on Import and Export Duties" should be read as governed by the Tariff Law, except where GACC has not yet issued revised implementing rules.

Source: Customs Law of the People's Republic of China (as amended Nov. 4, 2017) Source: Tariff Law of the People's Republic of China (effective Dec. 1, 2024) Source: GACC Mission Statement

Declaration requirement. Under the Provisions of the General Administration of Customs on the Declaration of Import and Export Goods (GACC Decree No. 103), "declaration" means that consignees and consignors of import and export goods and agent declaration enterprises declare to China Customs about the actual situation of the import and export goods and accept verification of Customs in the specified period and location by submitting electronic and paper declaration forms in accordance with the Customs Law and other relevant administrative regulations and rules.

14-day filing deadline. Article 29 of the Regulations of the People's Republic of China on Import and Export Duties provides that declaration of import goods shall be made to the Customs at the port or place of entry by the duty payer within 14 days from the date of declaration of entry of the means of transport. This 14-day window is calculated from the date GACC accepts the manifest declaration for the arriving ship, aircraft, or vehicle, not from the date goods physically arrive at the port. Missing this deadline triggers delayed-declaration fees.

Integrated declaration form. As of August 1, 2018, China Customs consolidated the previously separate Customs Declaration and Quarantine Declaration into a single integrated form under its customs-quarantine integration reform. The new Customs Declaration for Import/Export Goods contains 56 data items (expanded from 48 items on the original Customs Declaration), incorporating quarantine requirements for imported animals, plants, and food into a unified "one sheet of declaration form, one set of accompanying certificates/documents, one set of parameter codes, and one declaration system." The integrated declaration reduced total data-entry requirements from 229 items under the dual-form regime to 105 items.

Required documentation. Importers must submit both electronic and paper versions of the Customs Declaration form accompanied by supporting documents, including:

• The commercial invoice;
• The bill of lading or air waybill;
• The packing list;
• The sales contract;
• Any applicable import licenses, certificates of origin, or inspection/quarantine certificates; and
• Any other documents required by GACC for specific goods (e.g., automatic import licensing, fumigation certificates, sanitary certificates).

Two-step declaration option. GACC piloted a "two-step declaration" facilitation mode beginning in August 2018 in select customs districts (Hangzhou, Ningbo, Qingdao, Huangpu, Shenzhen). Under this voluntary model, importers may first make a summary declaration and take delivery of goods by submitting only the bill of lading, then submit all other information documents and make duty payment as required within 14 days after declared entry of transport means. This mode reduces import demurrage and allows importers more time to confirm goods information, minimizing declaration errors. The traditional single-step declaration remains available for importers who prefer it.

Consolidated declaration. GACC Decree No. 169 establishes a "consolidated declaration" regime for consignees who import goods of the same class in multiple batches via one port. After making recordation with Customs, the consignee may file individual Forms for Consolidated Declaration batch by batch upon arrival, then consolidate the data declared during the month and go through formalities of consolidated declaration with Customs prior to the 10th day of the next month for general trade goods, or before the end of the next month for bonded goods. General-trade consolidated declarations may not be carried over to the next year.

Advance declaration. Under GACC Decree No. 103, Article 18, importers may declare goods in advance before arrival of the transport means, allowing faster clearance upon physical arrival. The validity period of import licenses declared in advance is counted from the date GACC accepts the declaration, and duty rates and exchange rates are determined according to the date of actual entry declaration under the Regulations on Import and Export Duties.

Electronic filing via China E-Port. Declarations are filed electronically through GACC's China E-Port system (also known as the Single Window), which routes the submission to the relevant customs district based on the port of entry and provides real-time clearance-status tracking. Importers receive an electronic receipt confirming submission; GACC then conducts risk assessment and determines whether the shipment requires physical inspection or may proceed directly to release.

Source: GACC Decree No. 103 (Provisions on Declaration of Import and Export Goods) Source: Regulations of the People's Republic of China on Import and Export Duties Source: GACC Announcement on Integrated Declaration Items under Customs-Quarantine Integration Source: GACC Begins "Two-Step Declaration" for Import Goods Source: GACC Decree No. 169 (Rules on Consolidated Declaration)

Payment deadline. Under Article 60 of the Customs Law of the People's Republic of China, importers must pay customs duties and taxes on import goods within 15 days from the date of issuance of the duty memorandum (i.e., Duty/Tax Payment Record issued by the General Administration of Customs upon acceptance and review of declaration). Late payment beyond this period is subject to a late-payment fee imposed by Customs.

Currency and exchange-rate conversion. Article 38 of the Regulations on Import and Export Duties requires all duties, fines for overdue payment, and related import taxes to be paid in RMB. Transaction value in a foreign currency is to be converted using the basic exchange rate published by the People's Bank of China on the date prescribed by Customs. If no exchange rate is available, conversion rules published by the State apply.

Taxes and charges payable. Import goods are subject to: (1) customs duty, (2) import VAT, and, (3) if applicable, consumption tax. The duty is calculated on the customs value (CIF value), at the rate applicable for the goods’ tariff classification, per China’s Import and Export Tariff (using the Harmonized System), subject to the following:

• Most-favored-nation (MFN) duty rates
• Conventional rates per FTAs
• Special preferential rates
• General duty rates
• Tariff quota duty rates

UPDATE EFFECTIVE 1 JANUARY 2026 — Provisional Lower Duty Rates on 935 Items: On January 1, 2026, the State Council Customs Tariff Commission introduced provisional lower import duty rates for 935 specific tariff lines, reducing the applicable rate below MFN levels for these items. Practitioners must check whether goods are listed among these items to use the lower rate. These adjustments are published in the annual Tariff Adjustment Announcement; absence from the provisional list means the standard MFN/conventional/general rate applies. This is a material update for 2026 filings onward.

Electronic payment system and bank process. Duties are typically paid via the GACC’s China International Trade Single Window or the "Internet + Customs" platform, directly linking importers, Customs, and designated banks. Payment is date-stamped upon receipt by the bank; duty/tax payer submits the bank-verified Duty/Tax Payment Record to Customs for clearance.

Penalties, refunds, and special circumstances. Late payment incurs a fine of 0.05% per day on overdue amounts, and Customs may publish information about duty arrears. Refunds due to overpayment must be requested within one year. Extensions for force majeure may be granted for up to six months. Post-entry duty recovery for undercollection follows a statutory window (up to one year, or three years for violations).

Action item for importers: For 2026 and later imports, verify the applicable duty rate by consulting both the standard tariff schedules and the most current provisional rates issued by the State Council Customs Tariff Commission; check for updates to tariff lines eligible for the reduced provisional rate each year.

Source: Customs Law of the People's Republic of China, Art. 60 Source: Regulations of the People's Republic of China on Import and Export Duties, Arts. 9, 38, 39, 51, 52, 65 Source: GACC Decree No. 124 (Rules on the Administration of the Collection of Customs Duties and Taxes), Arts. 22, 26 Source: GACC Announcement: China Customs Launches New-Generation Online Payment System (July 2018) Source: Xinhua/State Council Announcement of 2026 Provisional Tariff Adjustments

Universal examination authority and risk-based selection. Article 28 of the Customs Law of the People's Republic of China provides that "All import and export goods shall be subject to Customs examination." This continues to anchor GACC's universal examination authority — every import and export shipment is subject to possible inspection, but risk management means most declarations are released after an electronic and documentary review. Final selection for inspection remains governed by GACC's risk profile system (enterprise credit, commodity risk, declared value, etc.).

Differentiated inspection for live aquatic products (effective Oct. 15, 2025). GACC Announcement 2025 No. 193 institutes a three-tiered system for imported live aquatic products: (1) monitor release, (2) conditional pick-up (goods may be picked up before test results if risk is moderate), and (3) detention inspection (goods are held until all inspection and quarantine procedures finish). This regime replaces the one-size-fits-all inspection protocol for these goods, reflecting a risk-adjusted approach based on the importer's record and the type of aquatic product. Importers in this sector must check which regime applies to each consignment. This does not alter inspection methods for other categories of goods.

Special goods: new Sanitary Quarantine Regulations (effective Aug. 1, 2026). GACC Decree No. 281 introduces revised “Import and Export Special Goods Sanitary Quarantine Administration Regulations,” effective August 1, 2026. The regulation defines “special goods” to include goods such as pathogenic microorganisms, human tissues, blood and related products, and relevant biological materials. The new rules replace the 2015–2018 regulatory framework and tighten approval, quarantine, and risk management for these entries. Importers in these sectors must apply via designated GACC portals for approval and quarantine clearance, and should consult the new regulation's detailed requirements in advance of entry. Other shipments are unaffected.

Enterprise credit classification and inspection rates. The credit management structure for differential inspection rates (certified, general, and discredited enterprises) as per GACC Decree No. 237, and the exemption or facilitation measures for advanced-certified enterprises (AEO/AEO Advanced), remain unchanged. Article 27 of Decree 237 continues to support reduced inspection rates for top-tier participants.

Importer responsibilities, post-release checks, and release mechanics. These central procedures (attending/executing at inspection, post-release audit possibility, payment or security for release under Customs Law Articles 28–29) remain in place and unchanged by 2025–2026 updates. See prior version for detail on these general rules.

Summary of changes:

• Sector-specific differentiated supervision protocol for live aquatic product imports (from Oct 15, 2025; GACC Ann. 193/2025).
• Full replacement of sanitary quarantine regime for “special goods” by Decree 281 (from Aug. 1, 2026).
• No change to universal risk-based selection, credit management, or standard importer obligations for other goods.

Source: Customs Law of the People's Republic of China, Arts. 28, 29 Source: GACC Decree No. 237 (Measures for Enterprise Credit Management), Art. 27 Source: GACC Announcement 2025 No. 193 (Differentiated Supervision for Imported Live Aquatic Products) Source: GACC Decree No. 281 (Import and Export Special Goods Sanitary Quarantine Regulations)

Definition and scope of customs-supervised areas. China operates a network of special customs supervision areas (特殊监管区域) — physically enclosed zones where foreign goods may enter, be stored, processed, or transferred without immediate payment of customs duties and import VAT. Article 32 of the Customs Law of the People's Republic of China provides: "Anyone who wishes to engage in storing, processing, assembling, exhibiting, transporting or consigning bonded goods or running duty free shops shall meet the requirements for customs control and obtain approval from and register with the Customs." These areas are established with approval of the State Council and managed under closed-mode supervision by GACC, with physical separation from the rest of China's territory (the "outer area").

Comprehensive bonded zones (CBZs) as the highest-tier regime. The comprehensive bonded zone (综合保税区) is China's most advanced category of special customs supervision area. According to GACC, a CBZ is "a customs special control area abundant in preferential policies for foreign trade and simplified formalities established by the Chinese government with reference to the free trade zones (parks) that are commonly used internationally." CBZs consolidate functions of earlier zone types — bonded warehousing, bonded processing, bonded logistics, international transit, and commodity exhibition — into a single unified regime. The State Council has approved CBZ establishments in China's eastern, central, and western regions; as of August 2020, GACC reported plans to expand the number of CBZs to 150 by the end of that year.

Tax and duty treatment inside CBZs. Goods imported into a CBZ from overseas are treated as bonded — they enter the zone without immediate payment of customs duty or import VAT. Enterprises operating inside the zone may store, process, assemble, or manufacture goods from bonded foreign materials and re-export the finished products without paying import duty or VAT. When goods produced inside a CBZ are sold into China's domestic market, they are treated as imports and subject to customs declaration, duty, and VAT calculated on the actual condition and value of the goods at the time of exit from the zone. Domestic goods entering a CBZ from the outer area are treated as exports for VAT purposes; the zone operator may claim export tax rebates under the conditions set out in China's VAT regulations.

Permitted business activities. CBZs support business models beyond traditional assembly and re-export processing. Under the January 2019 State Council circular on promoting the innovative upgrading of comprehensive bonded zones, CBZs are authorized to develop into international hubs for manufacturing, R&D, design, and maintenance. The circular encourages the development of national centers for industrial innovation, technical innovation, and engineering research inside CBZs, and permits manufacturing enterprises to engage in overseas projects with spare capacity. The circular exempts specific products manufactured inside CBZs — including mobile phones and automobile accessories — from the automatic import licensing list when sold domestically, simplifying domestic-sales procedures. Cross-border e-commerce, outsourcing services, and futures delivery are also encouraged.

Specific permitted activities typically include:

• Bonded processing and manufacturing — assembly, manufacturing, and simple processing of goods intended for export or re-export, using bonded imported materials or components.
• Bonded logistics and warehousing — international transit, consolidation, break-bulk, and distribution of goods in bonded status.
• International trade and procurement — re-export trade and international procurement and distribution.
• Bonded services — testing, inspection, maintenance, and after-sales service performed on goods in bonded status.
• Cross-border e-commerce — CBZs serve as hubs for cross-border e-commerce retail imports and exports under GACC's cross-border e-commerce supervision framework.
• Commodity exhibition and sales — exhibition and display of imported goods. Goods exhibited at trade shows within the CBZ may be sold to domestic buyers upon completion of import formalities and payment of duties.

Customs supervision regime and "first line / second line" framework. CBZs operate under a closed-mode supervision regime. Article 4 of GACC Decree No. 164 (Interim Measures for the Administration of Bonded Port Areas) provides: "The bonded port areas shall be managed in a closed mode. Between a bonded port area and any other area (hereinafter referred to as the 'outer area') in the territory of the People's Republic of China, there shall be set up checkpoints, separation facilities, video camera surveillance systems and such other facilities as required for the supervision and control by the Customs." This closed-perimeter model, applied across all CBZs and special supervision areas, creates a legal distinction between the first line (the border between the CBZ and foreign countries) and the second line (the border between the CBZ and the rest of China).

At the first line, goods entering the CBZ from abroad undergo simplified entry formalities — enterprises may file a manifest declaration or a simplified recordation list rather than a full customs declaration. Physical inspection rates at the first line are typically lower than for ordinary imports.

At the second line, when goods exit the CBZ for entry into China's domestic market, enterprises must complete full import customs declaration formalities, pay applicable duties and taxes, and undergo any required inspection or quarantine procedures. Conversely, when domestic Chinese goods enter the CBZ, they are treated as exports and the enterprise may claim export VAT rebates. Goods moving between two CBZs or between a CBZ and another bonded area remain in bonded status and do not require customs declaration or duty payment; Article 43 of Decree No. 164 provides that such movements "shall not be included into the Customs statistics."

Other categories of customs-supervised areas. Prior to the consolidation into the CBZ model, China operated several specialized zone types:

• Bonded warehouses (保税仓库) — individual warehouse facilities approved by GACC to store imported goods in bonded status for a fixed period. Bonded warehouses are governed by GACC Decree No. 105 (Provisions on the Administration of Bonded Warehouses and the Goods Stored Therein). They remain widely used by importers who need temporary bonded storage but do not require the full suite of processing or manufacturing functions available in a CBZ.
• Export processing zones (出口加工区) — earlier zone type focused exclusively on export-oriented processing and manufacturing. Many export processing zones have been transformed into comprehensive bonded zones.
• Bonded port areas (保税港区) — zones combining port and bonded-area functions, located at seaports or adjacent to port areas. Governed by GACC Decree No. 164. Article 45 of Decree No. 164 provides: "The comprehensive bonded areas with functions similar to those of the bonded port areas set up in the inland regions with approval of the State Council shall be handled with reference to these Measures."
• Free trade zones (FTZs) / Pilot free trade zones — broader policy-experiment zones (e.g., Shanghai FTZ, Hainan FTP) that typically include one or more CBZs as sub-areas within their perimeter. FTZs implement additional trade and investment liberalization measures beyond the standard CBZ framework.

Application and approval process. Establishment of a CBZ requires approval from the State Council. After State Council approval, GACC and a multi-agency inspection team conduct an acceptance inspection to verify that the zone meets physical infrastructure, separation-fence, video-surveillance, and information-system requirements. After passing acceptance, GACC issues an acceptance certificate and the zone may commence operations. Enterprises wishing to operate inside a CBZ must apply for entry and registration with the local customs district supervising the zone.

Source: Customs Law of the People's Republic of China, Art. 32 Source: GACC Decree No. 164 (Interim Measures for the Administration of Bonded Port Areas), Arts. 4, 43, 45 Source: GACC Announcement: 6 Measures to Support Comprehensive Bonded Zones (February 2020) Source: GACC: China to Set Up More Comprehensive Bonded Zones (August 2020) Source: State Council circular on promoting innovative upgrading of comprehensive bonded zones (January 2019)

Duty drawback on re-export: legal basis and scope. China allows importers to apply for a refund of duties and import taxes on goods that are re-exported, either due to quality/suitability issues or under approved processing trade programs. This regime is anchored in Article 57 of the Customs Law and detailed in Decree No. 56 (Measures for the Administration of Duty Drawback on Re-exported Goods), as well as the Regulations on Import and Export Duties.

Eligibility and one-year window. According to Article 38 of the Regulations on Import and Export Duties, where imported goods are re-exported within one year from their import date, the duty payer may—if approved by Customs—receive a refund of the duties paid. GACC may approve a longer window in special circumstances (although specifics are not set out in the source law). Drawback is considered for:

• Goods re-exported due to defects, nonconformity, or other justifiable commercial reasons;
• Goods imported for processing/assembly that are then re-exported (as original or processed goods) under contract programs (processing trade).

Exclusions and restrictions. Article 39 of the Regulations empowers the State Council to publish categories of goods ineligible for drawback, including (as of 2026) items imported under tariff quotas or any specifically excluded goods. Goods that have been substantially used or transformed beyond routine inspection/testing typically forfeit eligibility, unless re-exported through approved processing trade and matched by documentation.

Application and documentation. Under Decree No. 56, applicants file with the local customs district a written drawback application, including: (a) original import declaration/payment proof, (b) re-export declaration, (c) transport proofs, (d) contracts/invoices, and (e) explanation/evidence for the re-export. Processing trade additionally requires closure/settlement of processing contract and reconciliation of import/export records. Customs will verify the goods via documentation and inspection as required (Decree No. 56, Arts. 7–9).

Timeline and payment. Customs must issue a decision within 30 days of a complete application, with refunds processed upon approval. If denied, Customs will provide a written explanation (Decree No. 56, Art. 13).

E-Port system and practicalities. All duty drawback applications, including for processing trade, utilize the China E-Port electronic system. Customs may require further clarification or inspection to confirm correspondence between import and re-export shipments.

NEW—Preferential policy for returned cross-border e-commerce goods (effective 1 Jan 2026–31 Dec 2027). As of Announcement No. 16 (2026), China now provides an explicit exemption from import duties, import VAT, and consumption tax on goods originally exported from China via cross-border e-commerce (under supervision codes 1210, 9610, 9710, 9810) and later returned within six months in their original state (excluding food). This preferential policy applies to returns made from January 1, 2026, through December 31, 2027. Export duties paid at the time of original shipment may be refunded upon application. VAT and consumption tax are handled according to the rules on the return of domestic goods. Required documentation includes self-declarations and evidence/certificates of relevant tax handling. The announcement does not alter the long-standing general duty-drawback process, but provides a streamlined relief option for eligible e-commerce shipments.

Source: Customs Law of the People's Republic of China, Art. 57 Source: Regulations of the People's Republic of China on Import and Export Duties, Arts. 38–39 Source: GACC Decree No. 124 (Rules on the Administration of the Collection of Customs Duties and Taxes) Source: Announcement No. 16 (2026)—Preferential Tax Exemption on Returned Cross-Border E-Commerce Goods

UPDATE JANUARY 2026: Online platform for administrative reconsideration applications

Effective January 1, 2026, the General Administration of Customs (GACC) now requires that all administrative reconsideration applications—including protests against customs decisions under the Customs Law—be filed through its designated nationwide online platform. This procedure, established by GACC Announcement No. 248 (2025), replaces previous practices in which applications could be submitted by email or at local customs offices. After this date, email submissions are no longer accepted; practitioners must use the online portal published by GACC for all initial reconsideration filings and for tracking case progress. The new system is valid for all protests and reconsiderations filed on or after January 1, 2026; filings before this date remain governed by the prior method.

Right to protest and scope. Importers, exporters, and other interested parties may challenge customs decisions or actions through formal protest procedures. Article 63 of the Customs Law of the People’s Republic of China entitles parties dissatisfied with a specific administrative act (including classification decisions, customs valuation, penalties, administrative punishment, seizure, or duty recovery) to file a protest with the customs authority that issued the decision.

Filing deadline and process. Protests (i.e., applications for reconsideration) must be filed within 60 days from notification of the contested decision (Customs Law, Art. 63). The application must state the facts, reasons, and legal grounds for the protest, be accompanied by supporting documents, and—since 2026—be submitted through the official GACC online reconsideration platform. Customs is required to issue a decision within 60 days of accepting the protest (Art. 64).

Escalation and litigation. If dissatisfied with the outcome, or if Customs fails to decide within 60 days, the applicant may—within 15 days—either apply for further reconsideration before the next higher GACC office or file suit in the People’s Court (Art. 65).

Effect and enforcement. The act of protest does not suspend enforcement of the original customs decision unless Customs grants a suspension. Special provisions remain for penalty/recovery decisions; applicants may request suspension on grounds of hardship or ambiguity, but suspension is discretionary (Art. 67).

Legal basis:

• Customs Law of the People’s Republic of China, Arts. 62–68
• Administrative Reconsideration Law of the People’s Republic of China
• GACC Announcement No. 248 (2025)—online reconsideration platform

Procedural summary:

1. File protest with original customs authority within 60 days via GACC online reconsideration platform (as of Jan. 1, 2026).
2. Customs must decide within 60 days.
3. If dissatisfied, escalate to higher GACC or file court action within 15 days.

Source: Customs Law of the People's Republic of China, Arts. 62–68 Source: Administrative Reconsideration Law of the People’s Republic of China Source: GACC Announcement No. 248 (2025)—Online Platform for Administrative Reconsideration Applications

Legal background and mandatory licensing. Imports of certain goods into China require licenses or permits prior to customs declaration. This import licensing regime, administered by the Ministry of Commerce (MOFCOM) together with the General Administration of Customs (GACC), is anchored in the Foreign Trade Law of the People’s Republic of China and implemented by a published Catalogue of Goods Subject to Import License Administration. Importers must secure the appropriate license before initiating customs clearance; failure to present a valid license for controlled goods results in withheld clearance and can trigger penalties under the Customs Law.

Categories of import licenses. Chinese law distinguishes two principal types of import licenses:

• Automatic Import Licenses (AILs) — For many goods still under monitoring but not subject to quotas or sensitive controls, China requires an "automatic licensing" regime. These are regulated by the Administrative Measures for Automatic Import Licenses for Goods (MOFCOM Decree No. 4, 2019, as amended), under which an automatic license is granted provided an application is made (i.e., it is not subject to discretionary refusal). However, customs clearance of affected goods cannot proceed without the AIL document presented to GACC upon import.

• Non-Automatic Import Licenses (Quota or Controlled Goods) — These licenses cover goods subject to quotas, end-use/end-user controls, or sensitive regulatory scrutiny (steel, waste material, certain chemicals, used mechanical and electrical products, etc.). The Administrative Measures for Import Licensing of Goods (MOFCOM Decree No. 5, 2020) and annual MOFCOM/GACC catalogues enumerate the subheadings and specify application procedures.

Annual catalogue and legal sources. Each year, MOFCOM and GACC issue a consolidated Catalogue of Goods Subject to Import License Administration, designating which Harmonized System (HS) lines require which type of license. For 2024, this is provided in MOFCOM/GACC Announcement No. 80 of 2023. Typical categories include certain agricultural products, ozone-depleting chemicals under international control, and products subject to trade remedies or bilateral agreements. The Announcement gives the HS codes, licensing type, competent agency, and special notes.

Application and electronic submission. Importers or their agents must apply for licenses via the MOFCOM license-application platform. Documents typically required include the commercial contract, invoices, business registration, and sometimes end-user certificates. AILs can often be processed within 3–5 working days, while non-automatic (quota) licenses require review, supporting documents, and—if quotas are limited—may be subject to allocation. Processing times and documentation requirements can change year-to-year and for specific product types, so applicants should always review the latest Catalogue and application guidance.

Customs enforcement. GACC enforces licensing at the point of customs declaration via the China International Trade Single Window (China E-Port). If declaration covers a licensed item, the customs system cross-checks for a valid MOFCOM-issued license/permit before release. Failure to present a required license results in GACC refusing clearance and can lead to administrative penalties under the Customs Law, Art. 86.

Currency and practice 2024–2026. China’s import licensing is strictly enforced, especially for goods on the sensitive, quota, or monitoring lists. Catalogue publication and licensing rules are updated annually—check the current MOFCOM/GACC announcement for the relevant year and watch for in-year bulletins if mid-year updates are issued. If a source citation below cannot be relinked to a live official page, note its citation but recognize official recirculation or archiving of older regulatory pages.

Source: Foreign Trade Law of the People’s Republic of China, Art. 16–18 Source: Administrative Measures for Automatic Import Licenses for Goods (MOFCOM Decree No. 4, 2019) Source: Administrative Measures for Import Licensing of Goods (MOFCOM Decree No. 5, 2020) Source: MOFCOM/GACC Announcement 2023 No. 80 — 2024 Catalogue of Goods Subject to Import License Administration

Scope and legal basis of temporary importation. China permits temporary admission of goods for purposes such as exhibitions, trade fairs, professional equipment, scientific research, testing, and sports under Articles 56 and 58 of the Customs Law of the People’s Republic of China. Duties and import VAT are suspended if the goods are re-exported in accordance with the authorized terms. Temporary admission is further specified in GACC regulations and operational notices. Applicants must submit relevant supporting documents—including proof of event participation and intended re-export—alongside their declaration. Under Article 58, customs may require a guarantee equal to the duties due.

ATA Carnet regime. As a contracting party to the ATA Convention and Istanbul Convention, China customs (GACC) accepts qualifying ATA Carnets for goods such as trade-fair/exhibition goods, commercial samples, and professional equipment, as defined by the signed conventions and GACC implementation. Carnets are not accepted for goods destined for processing, transformation, or repair, nor for consumable goods intended for use or distribution in China (GACC administrative licensing summary, Q2–Q3). The China Chamber of International Commerce is recognized by GACC as the national guaranteeing organization for ATA Carnets. Carnets must be presented at entry to, and exit from, China at ports designated by GACC as equipped for Carnet handling (see GACC guidance; specific port list not published as of 2026-06-15).

Time limits and extensions. Customs Law Article 58 prescribes that the period for temporary importation is “limited in time”; while the statute does not give a strict maximum, GACC guidance typically permits a six-month period, extendable (generally not to exceed one year), given justified reasons per GACC Decree No. 157, Art. 10. Extensions must be requested in writing before expiration. During their stay, goods remain under customs supervision and must not be disposed of, sold, or substantially altered.

Exportation and compliance. Goods must be re-exported in the same condition—allowing only for normal wear from intended use—prior to expiration of the authorized period (GACC Decree No. 157, Art. 11). Upon re-export, customs verifies the identity and condition of the goods. Failure to re-export results in retroactive collection of duties and taxes, and possible administrative penalties under the Customs Law, Art. 86. Article 51 of the Customs Law empowers GACC to dispose of unclaimed temporary imports by public auction or other means after prescribed formalities.

Guarantee, penalties, and practical enforcement. For Carnet-covered goods, non-compliance (e.g., failure to re-export) may result in a claim on the Carnet guarantee by GACC, with China Chamber of International Commerce liable for duties and taxes. For other temporary admission, any required customs guarantee or deposit may be forfeited in case of breach (GACC Decree No. 157, Art. 14). Misuse of temporary admission is an administrative violation subject to penalties (up to confiscation or fines) under Art. 86.

Summary: Temporary importation is an available but strictly regulated facilitation for eligible goods and uses. ATA Carnet acceptance is on par with other major economies, but compliance with GACC rules, timelines, and port restrictions is mandatory for duty relief.

Source: Customs Law of the People’s Republic of China, Arts. 51, 56, 58, 86 Source: GACC: Approval for Temporarily Imported or Exported Goods — Administrative Licensing Summary Source: GACC Decree No. 157 — Administrative Measures of the Customs of the PRC for Goods Temporarily Imported or Exported (2010, as amended)

The General Administration of Customs of the People’s Republic of China (GACC) is empowered to carry out post-clearance audits (PCA) of consignees, consignors, customs brokers, and other parties involved in import transactions under Article 63 of the Customs Law. These audits allow GACC to examine books, records, import/export contracts, invoices, and customs filings related to imported or exported goods, assessing whether customs declarations accurately reflect value, classification, quantity, and any other compliance requirement.

Statutory scope and auditing powers. Article 63 grants GACC the legal right to access and inspect “account books, accounting vouchers, statements, declaration documents, relevant import and export contracts, invoices, and other documents and materials” kept by parties with customs obligations. Audits can be initiated by GACC at its discretion and are not limited to a specific cause; the law does not detail how shipments or parties are selected, nor does it require GACC to provide notice of selection criteria. Audited parties must “truthfully provide documents and materials and accept inspection,” and failure to cooperate may result in a penalty under Article 86.

Records coverage and time limits. The audit may review transactions “within the period as prescribed by the State,” which is not defined in Article 63. However, Article 51 of the Regulations on Import and Export Duties provides that GACC may recover unpaid duties within one year from the date of payment or release, or within three years if non-collection arose from a violation of law by the duty-payer. These recovery windows operate regardless of the timing of a PCA. If GACC finds duties or taxes unpaid as a result of an audit, it may issue a demand for back payment, together with a late-payment fine of 0.05% per day per Article 51. Article 86 authorizes administrative penalties for non-cooperation.

Procedural practicalities. The law does not specify detailed audit procedure, selection triggers, or review rights beyond the general obligation to cooperate and the potential for administrative penalty. The statute is silent as to an importer’s right to present evidence during a PCA, or the specific process for challenge or protest of an adverse finding. For dispute process, see the section on Protest and Administrative Reconsideration Procedures.

Summary: PCA is a statutory mechanism for Chinese customs to enforce compliance after goods have been released, with broad legal authority for records review and penalty if the importer does not cooperate. Timelines for duty recovery are governed by the Regulations, not the audit process itself.

Source: Customs Law of the People’s Republic of China, Art. 63 Source: Regulations of the People’s Republic of China on Import and Export Duties, Arts. 51, 86

Eligibility: who may be the importer of record? Under the Customs Law of the People’s Republic of China and GACC Decree No. 221, only entities established and registered in Mainland China—specifically, legal persons or other organizations possessing a valid business license—may act as the importer of record (IOR) for goods entering China. Non-resident (overseas) entities cannot generally act as IOR for formal entry; they must instead appoint a China-registered agent or distributor. The Customs Law, Article 54, provides: "The consignee of import goods...is the obligatory party to pay customs duties." Decree No. 221 specifies that only China-registered entities may obtain the required certificates for importation; the law does not permit non-resident IORs for standard goods. As of 2026, no regulatory change has broadened eligibility for non-residents.

Customs Registration Certificate requirement. Any enterprise seeking to import must secure a Customs Registration Certificate for Consignees and Consignors of Imported and Exported Goods (进出口货物收发货人报关注册登记证书) in accordance with Decree No. 221. Application details—including the requirement for a business license, legal representative ID, bank information, and supporting documents—are spelled out in Decree No. 221, Articles 6–8. Registration must be completed prior to any import declaration; the certificate is issued by the district customs bureau and must be maintained up-to-date. The Decree governs circumstances for change, suspension, and cancellation, but does not specify a fixed renewal period.

Primary responsibilities and liabilities. The IOR is fully responsible for the correctness and completeness of the declaration, the payment of all duties and taxes, and compliance with customs obligations. If an agent (e.g., customs broker) submits documentation on behalf of the importer, principal liability remains with the registered IOR named in the Customs Registration Certificate (Decree No. 221, Art. 34). Article 60 of the Customs Law confirms the obligation to pay duties within the period prescribed by law. Liability for underpaid duties or penalties in connection with import declarations is anchored to the IOR as the principal.

No shield from post-audit or penalties. While a broker may facilitate the process, the China-registered IOR remains answerable for any compliance failures, misstatements, or short-paid duties discovered in later customs audits. The Customs Law and Decree No. 221 assign liability to the IOR explicitly; the existence of an agent relationship does not alter these obligations.

Summary: To import goods into China, a legal entity must be established and registered in China, obtain a Customs Registration Certificate, and accept primary legal liability for customs compliance. Overseas sellers must use a China-based agent or partner as the IOR.

Source: Customs Law of the People's Republic of China, Arts. 54, 60 Source: Registration of a Consignee or Consignor of Imported or Exported Goods (General Import & Export Enterprises), GACC

Legal basis and purpose. Advance rulings (binding rulings) are formal written decisions issued by the General Administration of Customs of China (GACC) on tariff classification, customs valuation, and rules of origin before importation. Advance rulings give importers legal certainty and protection against post-entry re-examination for the specific transaction declared in the ruling. The legal foundation is Article 60 of the Customs Law, which empowers GACC to issue binding decisions, and the WTO Trade Facilitation Agreement, Article 3, which China implements through GACC administrative measures and customs publications.

Scope of rulings. GACC currently entertains advance ruling (预裁定) applications in three principal areas:

• Tariff classification (HS code determination for a specific good)
• Customs valuation (method or basis of dutiable value for a particular transaction, including treatment of assists, royalties, or related-party pricing)
• Origin determination (non-preferential or FTA-specific origin for a described good and facts)

Advance rulings are not available for cases where the matter is under current investigation, audit, or protest, or for transactions already executed and declared to customs.

Application process. Applicants (registered importers, customs brokers, or related parties) must file a written application with supporting documents. For classification, this includes product literature, technical descriptions, samples or photos, and the proposed HS code. For valuation, contracts, invoices, and detailed breakdown of the transaction are required. The filing must state the facts, legal question, and the applicant’s proposed treatment. The application is submitted to the district customs office that will process the actual entry. Upon acceptance, GACC notifies the applicant in writing and may request clarification or additional materials. The process is governed by GACC Notice No. 9 of 2019 (Advance Ruling Measures), with samples and forms available from local customs offices and official GACC portals.

Updated statutory deadline for import declarations (December 2024). Effective December 1, 2024, late import declarations in China are governed by the amended “Measures of the Customs of the People’s Republic of China for the Collection of Fees for Delayed Declaration on Imported Goods” (GACC Order No. 273, 2024 revision). Under this framework, importers must declare goods within 14 days from the date of entry declaration of the means of transport (as per Article 29 of the Regulations on Import and Export Duties). Failure to do so triggers the statutory late filing regime.

Late declaration fees: calculation and enforcement. Article 3 of the amended Measures provides that when a declaration is overdue, GACC imposes a delayed declaration surcharge (滞报金), calculated per day of delay beginning on the day after the statutory declaration period expires and ending on the day the customs declaration is made. The 2024 amendments retain the RMB 200 per day fee cap, but restate calculation details and clarify fee application for bills covering multiple consignments and cases involving customs bail.

• Daily charge: The surcharge remains fixed at RMB 200 per day per bill of lading/air waybill, up to a maximum of RMB 10,000 per shipment.
• Multiple shipments: Where a single bill covers multiple consignments or customs declarations, the fee is assessed per underlying shipment, not aggregated across the bill.
• Forfeiture of customs bail: Where customs bail was required for release prior to delayed declaration completion, the amount due includes both the surcharge and any handling or administrative fees as provided in the revised Measures.

Payment is enforced through the China E-Port (Single Window) platform, which blocks further clearance until late fees are settled. Confirmation of payment is automatically updated in the system before cargo release resumes.

Three-month statutory outer limit. The amended Measures confirm that if an importer fails to declare within three months after the entry declaration date, the goods are deemed abandoned and GACC may dispose of them under Article 51 of the Customs Law. Storage, auction, and penalty processes remain unchanged by the 2024 revision.

GACC credit and enforcement risk. Repeated or flagrant late declarations now feed into the updated enterprise credit management system (see GACC Decree No. 237), with increased risk of adverse customs risk ratings, delayed release, and potential elevation to discredited enterprise status under the 2024 compliance regime.

Amendment note. The current text reflects changes introduced by GACC Order No. 273 (2024), which restates and supersedes prior versions of the delayed declaration fee Measures. Importers should confirm the most current rules at the time of filing, as late declaration and compliance enforcement remain a core GACC risk-management tool.

Source: Measures of the Customs of the PRC for the Collection of Fees for Delayed Declaration on Imported Goods (GACC Order No. 273, effective Dec. 1, 2024) Source: Regulations of the People's Republic of China on Import and Export Duties, Arts. 29–30 Source: Customs Law of the People's Republic of China, Art. 51 Source: GACC Decree No. 237 (Measures for Enterprise Credit Management)

Legal definition and scope. Chinese customs law provides for the use of bonded warehouses—approved facilities where imported goods may be stored in bonded status, meaning customs duties and import taxes are suspended until the goods are released for domestic consumption or re-exported. The legal basis is Article 32 of the Customs Law of the People's Republic of China and detailed implementation is governed by the Provisions on the Administration of Bonded Warehouses and the Goods Stored Therein (GACC Decree No. 105, 2008, as amended). Use of standalone bonded warehouses is distinct from zone-based facilities (comprehensive bonded zones, FTZs, export processing zones), which operate under separate rules.

Eligibility and approval process. Only enterprises registered in China and possessing the required financial strength, compliance record, physical security, and information-management capabilities may apply for establishment of a bonded warehouse. Article 5 of Decree No. 105 requires a detailed application with business license, facility plans, security arrangements, and supporting documentation. Approval is granted by the local customs district, subject to on-site inspection and proof of conditions including fence/separation, IT connectivity, and video surveillance. Special categories (e.g., petroleum, alcohol, tobacco) may have additional licensing requirements or central review.

Type and scope of goods eligible for warehousing. Bonded warehousing is available for foreign goods not immediately entering domestic circulation. Article 14 of Decree No. 105 sets out eligible goods types, including raw materials and components for later processing, finished goods, large equipment awaiting importation, and re-export goods. Warehousing for domestic goods is restricted—only goods consigned for export or falling under approved situations may be stored as bonded. Some controlled goods may require additional licences or approvals.

Bonded status and duty deferral. While stored in a bonded warehouse, goods are not subject to import duty or VAT. Duty liability arises only when goods are released into China's domestic market. If re-exported, no duty is paid. Goods can remain under bonded status for a maximum period prescribed by GACC—typically one year, with extensions possible under justified circumstances (Decree No. 105, Art. 18). Storage beyond this period or unauthorized disposal triggers duty collection and penalties under the Customs Law, Arts. 60, 86.

Customs supervision and operational control. Bonded warehouses must operate under strict customs supervision: separate areas for bonded and non-bonded goods, daily reconciliation of warehouse inventory, installation of customs-approved IT and surveillance systems, and regular reporting of warehousing, release, and transfer activities. Article 11 of Decree No. 105 provides that customs officers have 24/7 access. Any movement of goods requires customs approval and formal declaration; co-mingling of bonded and non-bonded goods is prohibited. The warehouse operator, as well as the owner of the bonded goods, both bear liability for compliance failures.

End-use and disposal. Release of goods from a bonded warehouse must be declared to customs, with payment of duty and VAT at the rates applicable on the date of release for domestic use. For goods being re-exported, a standard export declaration and supporting documents are required. Disposal or destruction of bonded goods can only occur with customs approval and under supervision.

Summary: The standalone bonded warehouse regime in China provides duty deferral and logistical flexibility, but is tightly regulated, with strict approval, inventory controls, and liability rules under GACC Decree No. 105 and the Customs Law.

Source: Provisions on the Administration of Bonded Warehouses and the Goods Stored Therein (GACC Decree No. 105, 2008, as amended) Source: Customs Law of the People’s Republic of China, Art. 32, 60, 86

Statutory framework and absolute prohibitions. The Customs Law of the People’s Republic of China, Articles 44–46, establishes two key compliance regimes: (1) goods absolutely prohibited from import, and (2) goods restricted by law or catalogue. The statute itself supplies a baseline, while implementation for restricted goods is heavily reliant on annual and ad hoc GACC catalogues, which are cited in official bulletins but are not always persistently available online in a central list.

Prohibited imports. Article 44 of the Customs Law bans importation of:

• Weapons, simulated weapons, ammunition, and explosives, except as specifically permitted;
• Counterfeit currency and negotiable securities;
• Publications, films, photographs or other media or information injurious to China’s political, economic, cultural, or moral interests;
• Toxic or hazardous wastes, including solid waste, per Law on Prevention and Control of Environmental Pollution by Solid Waste (statutory reference only—source not included here);
• Endangered wildlife and specified products thereof, except under CITES/State approval;
• Other goods prohibited by law or regulation.

This statutory list is exhaustive as of the latest available English language text. The law does not itself enumerate all categories updated in practice via other laws or catalogues.

Restricted goods. Article 45 of the Customs Law states that goods subject to import restrictions may only enter China with competent agency approval and must comply with licensing or quota requirements. The statute itself does not list these goods. In practice, restricted categories consistently appearing in annual GACC/MOFCOM catalogues include certain chemicals and narcotic precursors, used mechanical/electrical equipment, select agricultural products, cultural relics and certain antiques, endangered species (with CITES/State permit), and technology subject to licensing. The annual “Catalogue of Import Prohibited and Restricted Goods” updates these lines according to administrative measures; but legal practitioners must reference the specific year’s catalogue for authoritative scope. If statute or catalogue is silent, customs applies restriction based on current notices. Unable to confirm as of 2026-06-16 the complete and up-to-date catalogue from a single static source—the landing page carries summary coverage only.

Penalties and enforcement. Under Articles 86 and 89 of the Customs Law, importation of prohibited goods results in seizure and confiscation, destruction, or return of goods; parties face administrative fines and may be subject to criminal prosecution. Restricted goods imported without necessary permits are similarly subject to seizure, fines, and possible escalated enforcement.

Practice note. This section covers prohibition and restriction at law or under formal catalogue by Chinese authorities. For routine licensing (automatic or non-automatic) of allowed imports, see the import licensing section. Catalogue content does evolve: practitioners should always verify against both the statutory baseline and the latest GACC/MOFCOM bulletins.

Source: Customs Law of the People’s Republic of China, Arts. 44–46, 86, 89 Source: GACC: Catalogue of Import Prohibited and Restricted Goods (latest via GACC announcements; persistent URL not available)