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 dedicated manuals (ledgers) with [M] marked in the first position of the header remarks column, and 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 temporary export (to Hong Kong) followed by re-import to circumvent bonded circulation restrictions and avoid 84% tariffs on all US-origin materials for domestic sales.

Specific Operational Procedures

Entry filing

• When US-origin materials enter the zone, mark [M] in the header remarks column of processing trade manuals (e.g., E-ledgers).
• Separately list US-origin materials in Bonded Verification Lists 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) with 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, note Hong Kong round-trip transit re-import in the customs declaration remarks column and reference the original export number.
• If domestic sales are required, they can beMay 13, 2025 24:00Declaration, with remarks .

Key Risk Control

1. Timeliness
   • The entire process must be completed within 14 days, otherwise it may be deemed false export by customs, resulting in domestic sales taxation (84% tariff on all US-origin materials).
   • If the goodsbefore April 10, 2025 12:01Already shipped goods may apply the goods in transit rule (Article 2 of the announcement), but must bebefore May 13.
2. Consistency of documents
   • Hong Kong transport documents (bills of lading, manifests) must show 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 transit 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.

Related recommendations:Interpretation of the Announcement of the General Administration of Customs on Matters Concerning the Implementation of Additional Tariff Measures on Imported Goods Originating from the United States,