Does commissioned processing fall into the category of export trade?

According to the "Customs Administrative Measures for Processing Trade" implemented in 2025, commissioned processing is essentially aSpecial trade methods, and its export attribute depends on the specific operational model:

• Processing with imported materials (Customs supervision code 0615): The ownership of imported raw materials belongs to the domestic enterprise, and the export of finished products is regarded as general trade export
• Processing with supplied materials (Customs supervision code 0214): The ownership of raw materials belongs to the overseas client, only a processing fee is charged, and the export is declared based on the processing fee
• Processing outside a bonded zone: Special supervision zone policies apply, requiring a separate declaration for the export of processing services

How to declare commissioned processing exports in 2025?

The latest customs declaration form requirements specify:

• The trade method column must be accurately filled with the supervision code
  • Declarations for processing with supplied materials must also provide theProcessing trade manual number
  • Processing with imported materials requires submission of theVerification form for imported materials
• Cargo Value Declaration Differences
  • Processing with supplied materials: Only declare the processing fee and the value of domestic auxiliary materials
  • Processing with imported materials: Declare the full value of the finished product

Can commissioned processing exports enjoy tax rebates?

According to the revised draft of the "Administrative Measures for Export Goods Tax Refunds (Exemptions)" issued by the Ministry of Finance in December 2024:

• Processing with imported materials model
  • Starting from 2025, adifferentiated tax refund system will be implemented
  • The domestic value-added portion is refunded at 17%, while the tax corresponding to the imported materials is not refunded
• Processing with supplied materials model
  • Continues to implementexemption, no refundpolicies
  • Processing fee income is exempt from VAT

How to choose the optimal processing trade model?

It is recommended that enterprises evaluate from three dimensions:

• Cost control capability
  • Processing with imported materials requires enterprises to have raw material procurement bargaining power
  • Processing with supplied materials is more suitable for enterprises with strong order-taking and production capabilities
• Capital turnover needs
  • Processing with imported materials requires more capital but offers higher tax refunds
  • Processing with supplied materials has less financial pressure but limited profit margins
• Customs Supervision Risks
  • Processing with imported materials needs to bearmanual verification risksResponsibility
  • In case of material shortages in processing with supplied materials, one facesforfeiture of security depositChanges in payment methods

What are the key points of customs inspections in 2025?

According to the latest supervision guidelines from the General Administration of Customs:

• Focus on verifyingthe authenticity of unit consumption declarations
  • Requires enterprises to provide process flow charts and basis for loss calculation
• StrengthenDisposal of scraps and leftoversSupervision
  • Starting from 2025, it is mandatory to auction defective products through a platform designated by customs
• ImplementNetworked supervision of processing trade
  • Enterprises with an annual processing value exceeding 50 million RMB must connect to the Golden Customs Phase II system

Common operational error warnings

• Mistakenlyfinished products from processing with supplied materialsas general trade for export
• Unauthorized disposal ofbonded scraps and leftoverswithout declaring to customs
• ConfusionProcessing feeandpaymentWe have obtained the business filing certificate. We are well aware that when importing medical devices, it is necessary to ensure that the products have the corresponding Chinese medical device registration certificates. Even if an enterprise has the business filing, if the product does not have the corresponding registration certificate, it still cannot be legally imported. In addition, the model and specifications of the imported product must be completely consistent with the information on the registration certificate. Any discrepancies may lead to import obstruction. We will ensure that your products meet all registration requirements and smoothly enter the Chinese market.?Forex Settlement?Declaration
• Failure to handlemanual extension as requiredleading to overdue verification