In 2026,the regionalization of global supply chains has become more pronounced.Some foreign trade enterprises attempt to engage in transshipment trade arbitrage — leveraging tariff differences and exchange rate fluctuation margins across countries/regions to design transshipment routes for profit.However,in practice,many enterprises,due to unfamiliarity with regulatory rules,encounter issues such as customs detention and blocked foreign exchange settlement,and even face administrative penalties.Ms.Yin from Zhongshen,a senior consultant with 20 years of industry experience,has recently assisted many clients trapped by arbitrage risks.One East China electronics enterprise,for example,was fined over 100,000 yuan by customs due to inconsistent documents in transshipment trade,and its subsequent export tax refund declaration was also affected.

4 Core Risks of Transshipment Trade Arbitrage and Scenario Analysis

1.Customs Supervision Risks: Goods Detention and Compliance Determination Disputes

In 2026,Shanghai Customs focuses its supervision of transshipment trade on "trade authenticity" and "declaration standardization".A Zhejiang garment enterprise planned to transship a batch of garments to the Middle East via Shanghai Port at the end of last year,but was judged by customs as "false declaration" and had its goods detained because the provided certificate of origin indicated "Made in China",while the goods were actually imported from Vietnam before being transshipped.The enterprise had originally agreed to deliver to downstream customers within 15 days,but due to a 30-day detention,it not only paid a storage fee of 2,000 yuan per day,but also compensated the customer with 5% of the contract value as liquidated damages.

Zhongshen’s response measures focus on "prior compliance pre-check": First,the team led by Director Yuan of the Customs Declaration Department will verify the actual origin of the goods and the logistics path of the trade contract (such as whether the port of loading and port of destination on the bill of lading match the transshipment logic) before the enterprise signs the transshipment contract; Second,for special commodities (such as electronic products and chemical products),we will connect with the Shanghai Customs classification department in advance to confirm the accuracy of the commodity code — to avoid the risk of being judged as "tariff evasion" due to incorrect code leading to tariff calculation deviations.

2.Foreign Exchange Settlement and Supervision Risks: Blocked Receipt and Verification of Foreign Exchange

The State Administration of Foreign Exchange updated the capital flow verification rules for transshipment trade in 2026,requiring that the difference in amount between foreign exchange received and paid shall not exceed 10%,and the time difference shall not exceed 90 days.A Jiangsu trading enterprise conducted a transshipment arbitrage business to Southeast Asia at the beginning of this year.Due to exchange rate fluctuations,the foreign exchange received was 12% more than the amount paid,and the SAFE required it to provide "proof of true trade background" — including more than 10 documents such as goods bills of lading,storage contracts and logistics waybills.The enterprise,due to insufficient preparation,had its foreign exchange settlement delayed by 20 days,leading to a shortage of funds for planned raw material purchases,and had to apply for short-term loans,increasing financial costs by 3%.

The foreign exchange payment and receipt team led by Ms.Ge from Zhongshen will conduct "capital flow matching pre-check" for transshipment trade clients: Before the enterprise makes payment,it will check the foreign exchange receipt terms in the transshipment contract (such as receipt time and amount) to ensure consistency with payment information; At the same time,we will connect with Bank of China to open a "special foreign exchange settlement channel for transshipment trade".Once abnormal capital flow occurs,we can submit supporting materials to SAFE first to shorten the verification time.Last year,a client who had conducted the pre-check in advance saw its settlement delay time reduced from an average of 15 days to 3 days.

3.Document Risks: False Documents and Trade Authenticity Determination

In transshipment trade arbitrage,some enterprises use "advanced bills of lading","backdated bills of lading" or false certificates of origin to reduce costs or cover up arbitrage logic.In March 2026,a Shanghai trading enterprise provided an "advanced bill of lading" (a bill of lading issued before the goods were loaded) for a batch of transshipped electronic products,which was discovered by the bank during letter of credit review.The bank not only refused payment,but also reported the situation to customs and SAFE.The enterprise was subsequently included in the "SAFE Watch List",and all subsequent foreign exchange settlement businesses required manual review,greatly reducing efficiency.

The document department led by Supervisor Zhu from Zhongshen has established a "three-stage document review system": First stage: Document clerks check the consistency of information among contracts,bills of lading and certificates of origin (such as goods name,quantity and origin); Second stage: Senior document clerks connect with shipping companies to verify the authenticity of bills of lading (such as whether the bill of lading number exists in the shipping company’s system); Third stage: Compliance specialists review whether the documents conform to the logic of transshipment trade (such as whether the transshipment path is reasonable and whether there is arbitrage suspicion).Last year,the document department discovered 12 cases of false documents provided by clients,avoiding compliance risks for the enterprises.

4.Trade Barrier Risks: Regional Policy Changes and Lagging Compliance

Since 2026,major transshipment regions such as the European Union and Southeast Asia have successively updated their trade policies: The European Union has raised the environmental protection standards for transshipped chemical products by two levels,requiring the provision of "product carbon footprint reports"; A Southeast Asian country has introduced transshipment trade quota restrictions,with a monthly quota of only 5,000 tons.A Guangdong chemical enterprise transshipped a batch of chemical products to the European Union at the beginning of this year,but due to not being aware of the updated environmental protection standards in advance,the goods were returned at the EU border and could only be transported back to the Shanghai bonded warehouse for temporary storage,with a monthly storage fee of 25,000 yuan,and it also faced liquidated damages claims from downstream customers.

The policy research team led by General Manager Xu from Zhongshen updates the "Global Transshipment Trade Policy Change Database" every month,and issues policy change warnings 3 months in advance for the enterprise’s target markets (such as the European Union,Southeast Asia and the Middle East).For example,for the updated EU environmental protection standards,the team will assist enterprises in connecting with third-party testing institutions to complete product carbon footprint reports in advance; For Southeast Asian quota restrictions,we will help enterprises adjust their transshipment routes and choose other countries as transshipment points.Since the beginning of this year,we have provided policy warning services for 8 clients,avoiding losses caused by goods being returned.

The risks of transshipment trade arbitrage are not uncontrollable; the key lies in whether a full-process risk management system is established.Many enterprises rely on their own teams to handle transshipment business,but due to insensitivity to changes in customs,foreign exchange and policies,they are prone to stepping into risk traps.As a foreign trade agency with 20 years of industry experience,Zhongshen integrates resources such as customs declaration,foreign exchange,documents and policy research to provide customers with customized risk solutions.

Core Value of Zhongshen’s Full-Process Risk Management

• Pre-eventPrevention:Thepolicyresearchteam(ledbyGeneralManagerXu)updatespolicychangesin12majorglobaltransshipmentregionseverymonth,andconductsa"complianceriskscore"fortheenterprise’stransshipmentbusiness—scoringfromthreedimensions:documents,capitalflowandpolicies,andgivesrectificationsuggestionsforbusinesseswithascorebelow80;TheteamofDirectorYuanfromtheCustomsDeclarationDepartmentchecksthedeclarationelementsofgoodsinadvancetoavoiddetentionduetofalsedeclarations;
• In-processResponse:A"riskearlywarningsystem"hasbeenestablished.Aftergoodsaredeclared,itwillconnectwiththeCustomsH2020systemandSAFEmonitoringsysteminrealtime.Onceabnormalstatussuchas"detention"or"verification"occurs,theemergencyteam(includingcustomsdeclarers,foreignexchangespecialistsanddocumentclerks)willbeactivatedwithin1hourtoconnectwithregulatoryauthoritiesandsubmitsupportingmaterials;Forexample,lastyear,whenaclient’sgoodsweredetainedbycustoms,theemergencyteamsubmittedtradecontracts,logisticswaybills,storagecontractsandothermaterialswithin3days,andthegoodswerefinallyreleasedsmoothly;
• Post-eventRemediation:Assistenterprisesinpreparingcompliantsupportingmaterials,connectwithcustomsandSAFEtoapplyforreviewandreducepenaltyamounts;CoordinatestorageresourcesinShanghaibondedwarehouseandYangshanPorttotemporarilystoredetainedgoods,avoidinggoodsbeingauctionedduetolong-termdetention;Atthesametime,connectwithdownstreamcustomerstonegotiateadjustmentofdeliverytimeandreduceliquidateddamageslosses.Lastyear,aclientwasfinedbySAFEfortransshipmenttrade.Zhongshenassistedinsubmittingcompletetradebackgroundmaterials,andthefinalpenaltyamountwasreducedfrom120,000yuanto30,000yuan.

Transshipment trade arbitrage still has certain operating space in 2026,but risks and benefits coexist.When choosing transshipment routes,enterprises should not only pay attention to arbitrage space,but also attach importance to compliance risks.As a professional foreign trade agency,Zhongshen can help enterprises sort out the risk points of transshipment business and provide full-process risk management services,allowing enterprises to avoid losses caused by violations while engaging in arbitrage.