Selling into China through a bonded zone: what you defer, and what you still owe

A comprehensive bonded zone (综合保税区) lets imported goods wait without tariff or import VAT, paid only on release into China and never if re-exported. It defers tax; it does not waive certification, Chinese labelling or an anti-dumping or retaliatory tariff. Only the cross-border e-commerce retail routes skip first-import registration, and they sell only to consumers.

Bonded warehousing is pitched to foreign brands as a way into China without paying duty. It is a way of paying duty later, which is worth a great deal and is a different thing. The route that changes what a brand has to register is narrower, and most English-language summaries run the two together.

What does “bonded” actually buy you?

Time and optionality, not a smaller tax bill. Goods entering a comprehensive bonded zone from abroad are bonded (予以保税) (GACC Order No. 256, Article 11), and when they leave for the domestic market they pay tariff and import-stage taxes on their state at that moment (Article 18).^⁠[1] Goods that leave for another country never pay Chinese import tax at all.

So stock can be positioned in China before a buyer exists for it, the tax on a container is paid only as each part of it is released, and stock that does not sell can go back out. The principle will be familiar from a US foreign-trade zone or an EU free zone. The mechanics differ.

	While goods are stored	When tax is paid	Legal status
China: comprehensive bonded zone	No tariff or import VAT	On release to the Chinese market, with an option to pay tariff on the imported inputs if the goods were processed in the zone	A special customs supervision area
US: foreign-trade zone	Admitted in foreign status, before any duty	When goods leave the zone for the US market	A site licensed by the Foreign-Trade Zones Board
EU: free zone	Held free of import duty and VAT	On release for free circulation	An enclosed area inside the Union’s customs territory, not outside it

Which way into China do your goods take?

One of four customs routes, and the route, not the warehouse, decides when tax is paid, at what rate, and whether the product needs Chinese registration before it can be sold. That last column is the one most brands miss.

Route	Tax falls due	Rate	First-import registration	Who can buy
General trade import	At the border	Full tariff and import VAT	Required, as the product category demands	Anyone, including a distributor
General trade through a bonded zone or warehouse	On release to the domestic market	Full rates, assessed on release	Required on release, exactly as above	Anyone, including a distributor
Cross-border e-commerce bonded import(1210)	On each consumer order, as it ships from the zone	0% tariff; import VAT and consumption tax at 70%, within limits	Not required: regulated as goods for personal use	Consumers only, for personal use
Cross-border e-commerce direct purchase(9610)	On each consumer order, shipped from abroad	As 1210	Not required	Consumers only, for personal use

The second row is where the pitch overreaches. A bonded warehouse changes when you pay; it does not change what the product must hold before a Chinese distributor can sell it. The registration column changes only on the last two rows, and those two rows only ever reach consumers.

How long can goods stay bonded?

It depends on the facility, and “indefinitely” is true of only one of them. A comprehensive bonded zone sets no storage period unless another law does (Order No. 256, Article 33).^⁠[1] A B-type bonded logistics centre allows two years; an extension needs good reason and the supervising customs office’s consent and, except in special circumstances, runs no more than one year (Article 24).^⁠[7] A bonded warehouse allows one year; an extension needs good reason and customs consent and, except in special circumstances, runs no more than one year (Article 22).^⁠[8]

A bonded warehouse’s clock is short enough to matter for slow-moving or seasonal stock. Goods still there at the end of the period, and neither re-exported nor imported, are dealt with by customs (Article 27).^⁠[8] The four clocks, and why the two kinds of logistics centre differ, are set out in how long goods can stay in a Chinese bonded warehouse.

New facilities keep appearing, so ask which kind an operator runs: its brochure will say “bonded” either way. Wenzhou, where we are based, has had a comprehensive bonded zone since the State Council approved it in March 2020;^⁠[9] Suqian’s B-type centre was approved on 20 December 2024.^⁠[10]

Can processing in a zone lower the tariff?

Sometimes, and only the tariff. Where goods processed or assembled in a comprehensive bonded zone are sold into China, the zone enterprise or the consignee outside the zone (区外收发货人) may choose to pay tariff on the imported inputs rather than on the finished product, and pays interest on the tariff that was deferred. Import VAT and consumption tax are still charged on the goods in the state they leave the zone (Order No. 256, Article 18).^⁠[1] The option began as a pilot and was extended to every comprehensive bonded zone from 15 April 2020.^⁠[11]

• It is worth something only when the finished product carries a higher tariff than its inputs. Where the inputs carry the higher rate, the ordinary basis is already the cheaper one.
• It is a tariff choice, not a tax choice. Import VAT is usually the larger number, and it is charged on the finished product regardless, at 13% for most goods under the VAT Law in force since 1 January 2026 (Article 10).^⁠[12]
• It does not apply where the finished product is one of the four kinds of measure goods. If the inputs were ordinary goods but the product falls under a tariff quota, a trade remedy, a suspended concession or a retaliatory tariff, tariff is charged on the finished product as it leaves (Announcement No. 83 of 2025, item 2(7)).^⁠[13]

What does bonded storage not change?

Everything the goods would have needed at the border, they need on release. Three things in particular.

• Licences and quotas. Goods leaving a zone for the domestic market that fall under tariff quotas or licence management still need the quota or licence (Order No. 256, Article 16).^⁠[1]
• Certification, registration and Chinese labelling. Released into general trade, bonded goods are ordinary imports.
• Anti-dumping, countervailing, safeguard and retaliatory duties. Since 10 June 2025, goods under tariff quotas, trade remedies, suspended concessions or retaliatory tariffs must be held in dedicated accounts in bonded areas, and cannot be bonded otherwise. Processed and sold into China, they pay tariff on all their bonded inputs with the measures applied; passed on through bonded channels, they may not be sold domestically at all; and cross-border e-commerce goods under a measure may not be moved into ordinary accounts (Announcement No. 83 of 2025, items 2(1), 2(2) and 2(6)).^⁠[13]

What is 1210 cross-border e-commerce bonded import?

The bonded half of the one channel that changes what a brand must register. Cross-border e-commerce retail import covers both 1210, where stock waits in a bonded warehouse, and 9610, where each order ships from abroad; the first-import rules are disapplied to both, and both sell only to consumers.^⁠[4] It is narrower than it sounds. Stock is shipped in bulk to a bonded warehouse inside a zone and released one consumer order at a time, through a platform connected to customs. Any city with a comprehensive bonded zone or a B-type centre can host it, Wenzhou included, once the local customs office confirms the site meets the supervision requirements.^⁠[14]

Rule	What it says
Regulatory status	Goods for personal use. First-import licences, registrations and filings do not apply, except to goods from epidemic areas whose import has been expressly suspended and goods for which emergency handling of a major quality or safety risk has been started
Tax	0% tariff; import VAT and consumption tax at 70% of the amount otherwise due. For a good at the standard 13% VAT rate with no consumption tax, that is 9.1%
Limits	RMB 5,000 per order and RMB 26,000 per person per year. An order holding a single item priced above RMB 5,000 but below the annual limit can still use the channel, at full rates
Which goods	Only those on the Cross-border E-commerce Retail Import Commodity List, last adjusted from 1 March 2022, when 29 items were added
Labels	The seller must tell buyers that goods bought directly from abroad may have no Chinese label and that a Chinese electronic label can be viewed on the website
The buyer	A consumer, for personal use. The goods may not be resold
Your party in China	A company registered in China, appointed by you, which registers with customs, carries the duty of truthful declaration and bears joint civil liability

What it cannot do matters as much. It cannot supply a distributor, a retailer or any business buyer. As a rule, bonded e-commerce stock may not be offered as bonded goods with offline pick-up outside a special customs supervision area.^⁠[4] And it does not replace the platform’s own onboarding. How the code works, and what a brand needs to use it, is in what 1210 bonded import is. Whether the no-entity route suits you at all starts with whether you need a Chinese company to sell in China.

Do you need a Chinese company to use a bonded zone?

Not necessarily your own, but someone in China has to be one. An enterprise operating inside a comprehensive bonded zone must be a registered market entity and register or file with customs (Order No. 256, Article 34).^⁠[1] For 1210 you appoint a company registered in China, which carries joint civil liability.^⁠[4] For general trade, the importer is a Chinese company: your distributor or a service provider. You need your own entity when you want to hold and sell the stock in China in your own name.

Does Hainan’s free trade port let goods into the mainland duty-free?

For goods traded into the mainland, only in one case, and only the tariff. Hainan began island-wide special customs operations on 18 December 2025:^⁠[16] the line between Hainan and the rest of the world is opened, and the line between Hainan and the mainland is controlled. Zero-tariff goods now cover about 6,600 tariff lines, 74% of the total,^⁠[17] up from about 21%.^⁠[18]

• Goods made in Hainan by an encouraged-industry enterprise, adding 30% or more in value there, enter the mainland free of import tariff; import VAT and consumption tax are still charged (财关税〔2025〕12号, item 3).^⁠[19]
• Separately, travellers leaving the island have an offshore duty-free shopping allowance of RMB 100,000 per person per year, with no limit on the number of purchases.^⁠[20]

For a brand, Hainan is a processing and regional-hub decision, not a back door to mainland consumers. The mainland line exists to stop zero-tariff goods reaching the mainland uncontrolled, and the 30% rule is a test of real processing by a qualifying enterprise.

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