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Managing market access barriers at the Chinese border

Commentary

Border agencies, namely China Customs and Commodity, Inspection and Quarantine (CIQ) are rolling out trade facilitation reform measures. Whilst this has been more prevalent in the China (Shanghai) Pilot Free Trade Zone the reform measures will eventually be implemented China-wide.

Simplifying import procedures and attaining consistency in rule interpretation and enforcement across multiple ports of entry is challenging and will naturally take time. That said the experience of importing into China need not be laden with hidden costs and nasty surprises. New Zealand exporters can still plan and partner with their designated China importers to operate an efficient import supply-chain.

Quantifiable data in respect of cargo inspection rates, cargo clearance times, and related challenges assists in supply-chain planning and performance measurement. Updated data was gathered in January 2015 from over 500 employees of foreign and domestic invested enterprises that generally work in a supply-chain or logistics role. Almost forty percent of the participants reported more than ten years of work experience in the field of customs and international trade.

Selected results are summarised below. Traders can use this information as a roadmap for benchmarking your supply-chain strategy and operating performance.

Who is doing the importing?

Eighty percent of companies are directly acting as the legal importer-of-record in order to tighten control – including foreign exchange remittance – and save service provider costs. Most companies are ranked as “A” which signifies a compliant track record and good standing with Customs. Under the new enterprise credit management rule the rank of the Importer should be published online. The remaining twenty percent of companies are still engaging a third party Import Agent to act as the legal importer-of-record. The Import Agent approach is more likely for New Zealand companies who tend to only have a light commercial footprint in China, prefer to ship and sell FOB, and trade product that requires import licenses from CIQ.

What are the likely Customs clearance times?

The average import clearance time to be expected is as follows:

•    For sea freight

o    15% Less than 3 days

o    36% 3 - 4 days

o    34% 5 - 6 days

o    15% More than 7 days

•    For air freight

o    30% Less than 2 days

o    15% 2 - 3 days

o    50% 4 - 5 days

o    4% More than 6 days

Almost half of all importers are using between two and three gateway ports and two-thirds use between two and four Customs Brokers.

What are the likely CIQ inspection rates and clearance times?

CIQ is the lead agency enforcing non-tariff measures (NTMs) such as sanitary or environmental protection measures, technical barriers to trade etc. NTM should be established based on scientific principles and uphold consumer health and safety. Exporters in the dairy, seafood, and food and beverage sectors must all comply with various NTM.

The average CIQ inspection rate to be expected is summarised is as follows:

Inspection Rate    Importer Experience

Lower than 5%    43%

5% to 10%    18%

10% to 30%    12%

30% to 50%    5%

Higher than 50%    4%

Don’t Know/Not applicable    18%

Imported product is typically Customs cleared first and then stored temporarily in a CIQ authorised non-bonded warehouse pending the outcome of the CIQ inspection and testing result. The average CIQ clearance lead time to be expected is follows:

•    51% Less than 3 working days

•    26% 3 – 5 working days

•    9% 5 – 10 working days

•    5% 10 – 20 working days

•    1% More than 20 working days

•    9% Don’t Know/Not applicable

First-time exporters to China in sectors such as food and beverage are required to complete an on-line registration with AQSIQ in advance of importation. They are also required to pre-register with the local in-charge CIQ the product label in accordance with the applicable National Standard (GB). The designated importer should also be registered with the local in-charge CIQ. Additional lead time should be planned for the first-time inspection and testing by CIQ.

Loss of Free Trade Agreement (FTA) benefits

Customs’ reserves the right to challenge the legitimacy of an FTA claim as lodged by the Importer. Checks typically take place upon arrival and declaration of the imported goods and they are made by the in-charge Port Customs. Importers can still expect to encounter the following practical challenges when using the FTA:

Issues raised by Customs    Rate

HS Code discrepancy between Country of Export and China    40%

Failure to satisfy the requirement of direct shipment (e.g. shipment was from Auckland via South Korea to Shanghai)    19%

Others (e.g. format or authenticity of the Certificate of Origin)    18%

“Loss of origin” due to 3rd party invoicing (e.g. invoicing was from New Zealand to Hong Kong to China)    12%

“Loss of origin” due to temporary storage (e.g. goods were stored temporarily in transit in Hong Kong)    7%

Third-country Customs is not able to issue a Movement Certificate (e.g. goods airfreighted via Sydney not accompanied by a Certificate of Non Manipulation).    3%

Resolution of issues

When Importers are challenged by Customs most of the checks are focused on the declared invoice value followed by the declared HS Code (tariff classification). Customs are well versed on certain industry invoicing practices and grey channel imports. Approximately forty-five percent of cases initiated by Customs resulted in additional duties being assessed. Additional financial penalty was only applied in eight percent of the cases. In order to resolve issues or to proactively make improvements the following action was taken:

Action Taken    Rate

Voluntarily met with Customs/CIQ to resolve issues    35%

Improved the shipping documentation accuracy    33%

Provided a cash/bank guarantee deposit to Customs    11%

Changed Customs Broker    7%

Changed Port of Entry/Exit    7%

Joined a new pilot program, such as the SPFTZ reform    6%

Other    1%

Summary

Customs and CIQ will continue to deploy simplified import procedures and to facilitate international trade. However, changing National Standards (GB) as published by AQSIQ and inconsistency in local port practices will remain a challenge in the short to medium term. The New Zealand to China end-to-end shipping process still requires approximately 20 documents. Only traders that are diligent in documentation accuracy and invest in relationships with Customs and CIQ at the port of entry can position themselves to enjoy fewer market access barriers at the Chinese border.

Contact

Damon Paling,

Partner, Customs & International Trade

PwC, Shanghai

damon.ross.paling@cn.pwc.com

Damon has 17 years’ experience in Asia advising companies on customs, trade and related supply-chain and market access matters, the last 11 years of which have been spent in Shanghai, China.