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

What “bonded” actually buys you

Under GACC Order No. 256, which has governed China’s comprehensive bonded zones since 1 April 2022, goods entering a zone from overseas are held bonded — 予以保税 (Article 11). There is no tariff and no import VAT while they are there. Tax is assessed when goods leave for the domestic market; goods that leave for another country never pay Chinese import tax at all.

What that buys a foreign brand is cash and optionality, not a smaller tax bill. 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 to anyone who has used a US foreign-trade zone or an EU free zone. The mechanics differ:

Four ways goods get into China

The question that decides cost and paperwork is not “bonded or not”. It is which of four customs routes the goods travel, because the route decides when tax is paid, at what rate, and — the part most brands miss — whether the product needs Chinese registration before it can be sold.

The second row is where the sales 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 only changes on the last two rows — and those two rows only ever reach consumers.

Zone, warehouse or logistics centre: the storage clock

“Bonded” covers several kinds of facility with different rules, and the one that most often catches a brand out is how long stock may stay.

A common summary says bonded goods can wait indefinitely. That is true of a comprehensive bonded zone and false of the other two — and a bonded warehouse’s clock is short enough to matter for slow-moving or seasonal stock. When the time runs out, the goods have to be imported, re-exported or dealt with by customs.

New facilities are still being created. Wenzhou, where we are based, has had a comprehensive bonded zone since the State Council approved it in March 2020; Suqian’s B-type centre was approved on 20 December 2024. An operator’s brochure will say “bonded” whichever kind it runs. Ask which, because the answer sets your clock.

Processing in a zone: the tariff choice

If goods are processed or assembled inside a comprehensive bonded zone and then sold in China, Article 18 of Order 256 lets the zone enterprise — or the buyer outside the zone — choose to pay tariff on the imported inputs rather than on the finished product, with 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. The option began as a pilot and was extended to every comprehensive bonded zone from 15 April 2020; Order 256 now writes it in.

Two consequences follow, and summaries usually get the second one wrong:

• The choice is only worth something when the finished product carries a higher tariff than its inputs. Where the inputs carry the higher rate, the ordinary basis — the finished goods — 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. China’s VAT Law, in force since 1 January 2026, kept the 13% rate on imported goods.

What bonded storage does not change

• Licences and quotas. Goods leaving a zone for the domestic market that need an import licence or fall under a tariff quota still need them (Order 256, Art. 16).
• Certification, registration and Chinese labelling. Released into general trade, bonded goods are ordinary imports. Whatever the product would have needed at the border, it needs on release.
• Anti-dumping, countervailing, safeguard and retaliatory duties. Since 10 June 2025, Announcement No. 83 of 2025 — issued by customs with five other departments — requires goods subject to tariff quotas, trade-remedy measures, retaliatory tariffs or suspended concessions to be held in dedicated accounts. Sold into China, they pay the full tariff and every applicable measure. Products made from them and transferred on through bonded channels may not be sold domestically, and such goods cannot be moved from cross-border e-commerce accounts into ordinary ones.

Cross-border e-commerce bonded import (1210)

This is the route that changes what a brand must register, and 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. The rules come from three instruments: a 2016 notice that set the tax, and two from the end of 2018 that set the limits and the supervision, in force since 1 January 2019.

What it cannot do matters as much. It cannot supply a distributor, a retailer or any business buyer: everything sold through it goes to a consumer for their own use. Bonded e-commerce stock may not, in principle, be offered as “bonded plus offline pick-up” outside a special customs area. And it does not replace the platform’s own onboarding — the corporate records, trademark and production evidence a platform asks of a foreign brand are a separate hurdle, and the one that stops most applications.

Brands usually take this route to test demand before committing to registration and a distributor. If that is the decision in front of you, start with do I need a Chinese company to sell in China?

Hainan: an island run as a bonded zone

On 18 December 2025 Hainan began island-wide special customs operations. The whole island now runs as one special customs supervision area: the “first line” between Hainan and other countries is opened up, and the “second line” between Hainan and the mainland is controlled.

• The share of tariff lines at zero tariff rose from 21% to 74%.
• Goods processed in Hainan that add 30% or more in value can enter the mainland tariff-free.
• The offshore duty-free shopping allowance is RMB 100,000 per person per year.

For a brand, Hainan is a processing and regional-hub question, not a back door to mainland consumers. The second line exists precisely to stop zero-tariff goods flowing into the mainland market uncontrolled, and the 30% threshold is a test of real processing.

The Chinese party you actually need to check

Every bonded route puts a Chinese company between you and your goods. In bonded general trade it is the operator holding your stock under its customs account. In cross-border e-commerce it is the agent that declares your goods, and which the rules make jointly liable. Due diligence on this route is not a factory audit — your manufacturer may be anywhere. It is checking the company that will hold your inventory and speak to Chinese customs about it.

1. Is it real, and registered to do this? The national registry shows status, legal representative and business scope — see what GSXT shows about a company.
2. Is it registered with customs, and how does customs rate it? The customs credit publicity platform is searchable by company name or Unified Social Credit Code and shows customs registration, credit grade and administrative penalties.
3. Is the company on your contract the company on the customs record? Confirm that the entity signing is the entity holding the registration.
4. Which facility, and whose account? A bonded warehouse with a one-year clock is a different commitment from a zone with none.
5. What happens to your stock if the relationship ends? Who can move goods out of the bonded account, to where, and on whose declaration.
6. Are your goods on the positive list? Check the list itself, not the pitch.

These are records questions rather than legal ones. They need someone who can read Chinese registry and customs records and put the questions to the operator in Mandarin — which is what a counterparty check does.

Quick FAQ

Do I pay import duty on goods in a Chinese bonded warehouse?

Not while they are there. Goods entering a comprehensive bonded zone from overseas are held bonded, with no tariff or import VAT. Tax falls due when they are released to the Chinese market, and never if they are re-exported. The clock differs by facility: a bonded warehouse allows one year, extendable by one; a B-type logistics centre two, extendable by one.

Can I sell in China without CCC or product registration if my goods come through a bonded zone?

Not through general trade. Goods released from a bonded zone into the domestic market need the same licences, certification, registration and Chinese labelling as any other import. The exception is cross-border e-commerce retail import, which is regulated as goods for personal use and exempt from first-import registration — but it sells only to consumers, within limits.

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

A customs route in which stock waits in a bonded warehouse and ships one consumer order at a time through a platform connected to customs. The tariff is 0%; import VAT and consumption tax are charged at 70% of the normal amount; orders are capped at RMB 5,000, and RMB 26,000 per person a year; and only goods on the positive list qualify.

Do I need a Chinese company to use a bonded warehouse?

Not necessarily your own. Cross-border e-commerce requires you to appoint a company registered in China, which registers with customs and bears joint civil liability. General trade needs a Chinese importer of record — 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.

Can a bonded zone get my goods round China’s anti-dumping or retaliatory tariffs?

No. Since 10 June 2025, goods subject to trade-remedy measures, retaliatory tariffs, tariff quotas or suspended concessions must be held in dedicated accounts. Sold into China they pay the full tariff and every applicable measure, and they cannot be moved from cross-border e-commerce accounts into ordinary ones.

Is a Chinese bonded zone the same as a US foreign-trade zone?

The principle is the same: goods wait without duty and pay only when they enter the domestic market. The detail is not. Inside a comprehensive bonded zone, China adds the option to pay tariff on the imported inputs rather than on the processed product — while import VAT is still charged on the finished goods.

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

Only goods processed in Hainan that add 30% or more in value. Island-wide customs operations began on 18 December 2025, with zero tariff on 74% of tariff lines, but the line between Hainan and the mainland exists to stop zero-tariff goods flowing inland. It is a processing decision, not a distribution shortcut.