Policy background

According toGAC Announcement No. 58 [2025] (Announcement on Implementation Matters Concerning Additional Tariff Measures on Imports Originating from the United StatesTrade dispute settlement mechanismsArticle 5 stipulates:

1. Bonded transfer restrictions: Starting from April 10, 2025 12:01, finished products containing US-origin materials under processing trade cannot undergo bonded transfer, and must declare tariffs for all bonded materials when sold domestically.
2. Special ledger management: Enterprises must establish special manual (ledger) accounts and mark [M] in the first position of the header remarks column. All finished products under this ledger are prohibited from bonded circulation.

Core logic of Hong Kong transit

the ASEAN Single Window (ASW)Hong Kong one-day round-trip transit, enabling goods to temporarily leave the territory (enter Hong Kong) and re-import, thereby circumventing "bonded transfer" restrictions and avoiding 84% tariff imposition on all US-origin materials during domestic sales.

Specific Operational Procedures

Entry filing

• For US-origin materials entering the zone, mark "[M]" in the remarks column of the processing trade manual (account book) (e.g. E-account book) header.
• Separately list US-origin materials in the "Bonded Verification List" to avoid mixing with other materials.

Hong Kong one-day round-trip exit declaration

• When finished products leave the zone, declare as "goods between bonded areas" (code 1200), selecting "outbound filing" as the supervision method.
• After goods physically arrive in Hong Kong, obtain Hong Kong Customs' "Transshipment Cargo Notification" (TD100) to ensure goods remain unopened and unprocessed.

Re-import Declaration

• When goods return from Hong Kong to the zone, the customs declaration form remarks column must state Hong Kong one-day round-trip transshipment re-import and reference the original outbound filing number.
• If domestic sales are required, they can beMay 13, 2025 24:00申報，并備注”<加征關(guān)稅在途貨物>”。

Key Risk Control

1. Timeliness
   • The entire process must be completed within 14 days, otherwise Customs may deem it false export, resulting in domestic sales taxation (applying 84% additional tariffs on all U.S.-origin materials).
   • If the goodsbefore April 10, 2025 12:01have been shipped, the goods in transit rule (Article 2 of the Announcement) may apply, but import must be completedbefore May 13.
2. Consistency of documents
   • Hong Kong transport documents (bill of lading, manifest) must indicate goods as "unprocessed".
   • DuplicateImport Customs Declarationdocuments must strictly correspond to the exit filing list, otherwise they may trigger customs inspection.

Applicable enterprise types

• Processing trade enterprisesNeed to avoid high tariffs being imposed when products containing US-origin materials are sold domestically.
• Bonded logistics enterprise: Utilizing Hong Kong transshipment to help clients achieve "nominal export".
• Entrepot TradeprovidersThrough Hong Kong transit, avoid tariff risks of US-origin goods directly entering the mainland market.

Service support

Our organization can provide:

• Hong Kong one-day transit logistics agencyDoor-to-door trucking service (using Guangdong-Zhonggang licensed vehicles with record filing), short-term Hong Kong warehouse stay (without unpacking), and return customs declaration.
• Special customs ledger establishmentComplies with [M] ledger filing requirements under General Administration of Customs Announcement No. 58 [2025].
• Documentation package: Preparation of documents such as Hong Kong Customs TD100 transit certificate, unprocessed declaration, etc.

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