How to understand the “clearance certificate”?
Answer: Friends who have done general trade imports know that legal inspection goods need to provide a clearance certificate issued by commercial inspection when declaring, otherwise the customs will not release them. The following is the definition of a clearance certificate:
Commodity inspection clearance certificate
The entry-exit inspection and quarantine agency authorized by the General Administration of Quality Supervision, Inspection and Quarantine of the People’s Republic of China issues a certificate that the consignee of imported goods or his agent has completed the inspection procedures for the inbound goods and special items included in the “Inspection and Quarantine Legal Inspection Catalogue” and those that are not included in the “Inspection and Quarantine Legal Inspection Catalogue” but are clearly required by the relevant laws and administrative regulations of the state to implement inspection and quarantine by the entry-exit inspection and quarantine agency.
The “Positive List” clearly stipulates that direct purchase goods are exempt from the verification of the clearance certificate, and online purchase bonded goods “online” need to verify the customs clearance certificate when entering the zone, and “second line” is exempt from the verification of the customs clearance certificate when leaving the zone. Cross-border e-commerce direct purchases are imported as a single order package, so it is obviously impossible to operate the customs clearance form. However, online bonded goods are imported in batches and are only temporarily stored in the bonded area, so there are conditions for customs clearance verification.
However, under normal circumstances, bonded areas (or other customs special supervision places) usually require customs clearance verification when the “second line” leaves the area. So why does online bonded shopping require the “first line” to provide a customs clearance form when entering the area? The reason is very simple. When online bonded goods leave the area on the second line, they are a single order package and do not meet the conditions for customs clearance inspection. Therefore, they can only be verified when the “first line” enters the area. This is what we call “pre-placement of customs clearance form”. Some people will say that the establishment of bonded areas is to facilitate enterprises to enter the area for operation, and its principle is “release the first line and control the second line”. This pre-placement of customs clearance forms is contrary to the original intention of bonded area supervision. I don’t think so, because the pre-placement of customs clearance documents is only for the bonded business of cross-border e-commerce online shopping, and other businesses in the bonded area are still operated according to the original “release the first line, control the second line”. In short, we can regard the “pre-placement of customs clearance documents” for cross-border e-commerce online shopping bonded as a special case of the bonded area. Why is there such a special case? As I said before, online shopping bonded goods do not meet the conditions for customs clearance document verification when leaving the area at the second line.
Another question is, why does online shopping bonded goods need to verify customs clearance documents? This involves the issue of access supervision at the commodity inspection level. General trade imports and online shopping bonded imports are both bulk entry of goods. The former requires customs clearance documents. To ensure fairness, the latter must also provide customs clearance documents.
Indeed, customs clearance documents have a great impact on cross-border e-commerce companies. In order to obtain commodity inspection customs clearance documents, companies must provide documents such as certificates of origin, official health certificates, and quality inspection reports. Obviously, those small and medium-sized import cross-border e-commerce enterprises that purchase goods from the market and wholesalers are basically unable to engage in online bonded imports, because they rarely meet the requirements of such customs clearance documents.
As for those large and powerful import cross-border e-commerce enterprises with centralized procurement, even if they are able to meet the requirements of customs clearance documents, they have to compare the advantages and disadvantages of general trade and bonded imports: which one is better in terms of tax costs (the tax-paid prices of the two are different); which one is better in terms of operating costs (the rent of bonded imports is obviously higher than that of general trade, but no tax is required when the goods are not out of the zone); which one is better in terms of convenience (bonded imports are very convenient for return as long as they are not out of the second zone). In this way, for small and medium-sized enterprises that cannot meet the requirements of customs clearance documents, bonded imports are dead; for large enterprises that can meet the requirements of customs clearance documents, bonded imports are still an option, but they must also compare with general trade before choosing the best one.
Of course, in actual operations, some places will have flexible practices. For example, in Guangzhou and other places, if the company cannot provide documents such as certificates of origin, official health certificates, quality inspection reports, etc., it can use overseas traceability certificates as a substitute. Overseas traceability certificates are issued by independent third-party impartial inspection agencies, and such agencies must have passed the professional inspection qualification assessment of the China National Accreditation Service for Conformity Assessment (CNAS) in advance.