Although the tax changes involved in the new cross-border import policy have increased a bit, they are generally acceptable to the industry. In addition to the new tax system, there is another change in the “commodity list management”, which is comparable to blowing out the lamp and pulling out the wax. Before the tax reform, cross-border e-commerce only had a “negative list” which stated which goods could not be imported.
The official statement is that a third-party test result acceptance system is implemented for imported high-risk e-commerce products, and low-risk products only need to provide a sales certificate or declaration of conformity. After the tax reform, it became a “positive list” that stipulates what goods can only be imported, which is based on the “Cross-border E-commerce Retail Imported Goods List” issued by the Ministry of Finance.
On the surface, the “Positive List” unifies the products that can be cleared at each port, and the product segmentation will be more standardized, which can improve the efficiency of import customs clearance. However, the “Positive List” requirement that “customs clearance forms” must be inspected upon entry has become the crux of this new policy. “Customs clearance form” is the customs clearance form for inbound goods. It is a document issued by the entry-exit inspection and quarantine agency authorized by the General Administration of Quality Supervision, Inspection and Quarantine in accordance with the law to prove that the inspection procedures for inbound goods have been completed.
The customs clearance form or order number must be provided when declaring to the customs, otherwise the order will be returned. To obtain a customs clearance form, the importer must provide certificate of origin, contract, invoice, packing list, waybill, relevant license/approval documents, relevant quarantine certificate issued by the Food and Drug Administration (cosmetics also need to provide Chinese label samples) , foreign language original labels, cosmetic ingredient lists and other materials), fill in the “Inbound Goods Inspection Form” to apply for inspection to the National Inspection and Quarantine Department, and establish a commodity ledger.
Compared with customs inspection, import and export inspection and quarantine focus more on the inspection of the physical and chemical characteristics of the goods themselves to determine their risks. Quarantine inspection and pest control of imported e-commerce commodities and their packaging, bedding materials, transportation vehicles, and containers shall be carried out in accordance with relevant regulations. Only after the inspection application is passed, the national inspection department will issue the “Inbound Goods Inspection and Quarantine Certificate” and the “Inbound Goods Customs Clearance Form”.
According to statistics, about 36% of the codes in the list are in the “Legal Inspection Catalog” and need to be inspected and released with a customs clearance form. The rest do not require a customs clearance form to go through customs clearance procedures. However, compared with the massive imported varieties of cross-border e-commerce, the goods on this list are still very limited. Many goods that could be imported through cross-border e-commerce in the past are now not on the list. This means that they must include both the filing information at the time of declaration (such as health certificates, etc.) and the specific inspection and quarantine implementation (such as sampling inspections, etc.) ).
However, imported cosmetics, food, health products and other products must be registered with the Food and Drug Administration, and the processing time can range from several months to more than a year. Moreover, it is difficult for most cross-border e-commerce companies to meet the requirements of direct cooperation with overseas suppliers. Those small and medium-sized import cross-border e-commerce companies that purchase goods from markets and wholesalers mostly do overseas shopping, that is, the procurement team or buyers are in Overseas supermarkets, stores and other places purchase goods in large quantities. This model obviously cannot obtain documents such as certificates of origin and contracts, which will force most goods to be taken offline.
Therefore, “front-loading the customs clearance form” has become the real trump card of this new policy. In order to weaken the impact of customs clearance orders on the industry, the State Inspection and Quarantine Customs has adopted the following approaches: first, exempting cross-border direct purchase imports from issuing customs clearance forms; second, setting the issuance of customs clearance forms at the “front line” when entering the bonded area, to avoid When the “second line” leaves the area, small packages are issued one by one, and customs clearance forms are paperless and docked with the customs to improve customs clearance efficiency.
After the release of the “Notice on Tax Policies for Cross-border E-commerce Retail Imports”, the impact was beyond expectations. “It is required that cross-border e-commerce imported goods shipped after April 8, 2016 must meet the positive list and “List Note Requirements” suddenly became a turmoil, industry confidence was severely dampened, and supply chain channels were greatly affected.
Half a month after the implementation of the New Deal, import B2C cross-border e-commerce orders in Ningbo, Hangzhou, Shenzhen, and Zhengzhou all fell by more than 60%. The foreign Australian milk powder market experienced panic, and several countries such as A2/SW/BM The stocks of the company plummeted, the CEO of Deyun was forced to resign, and the purchase price of the popular Kao diapers was reduced by half, which shows the great impact of China’s cross-border market on foreign brands.
The policy had to be urgently implemented, coordination content was introduced, and the positive list system was suspended for one year, but it was limited to the ten cross-border pilot cities approved in the early stage, and the second batch of pilots was not among them. In fact, the government is in a difficult position due to changes in regulations. The essence is that how to determine the nature of the emerging business of imported B2C cross-border e-commerce, while ensuring fair taxation, fair trade, and traceability of consumer product quality and safety, requires a high degree of wisdom.
In November 2016, the Ministry of Commerce issued a temporary notice to extend the transition period for cross-border e-commerce retail import supervision. Obviously, there is no means to take shape yet. After the transition period, the positive list will only be suitable for those categories for which domestic e-commerce has large-scale demand. Of course, it is also suitable for general trade imports. For cross-border long-tail niche products, it is still difficult to perform registration and inspection procedures, and there are few cross-border products. Overseas enterprises can meet the customs clearance requirements for general trade.
If economies of scale cannot be achieved, cross-border e-commerce will not be easily squeezed into trade. In the future, cross-border imported goods will be supervised as “goods”, and the supervision of bonded imports will be almost equal to that of general trade. Cross-border e-commerce will lose the low entry threshold, and long-tail products will be directly cut off, exacerbating the same problem. Qualitative competition…Fundamentally speaking, imported retail channels still need to be fair, and online and offline will not always be two trends.