Recently, the General Administration of Customs (GACC) issued Announcement No. 116 [2025] (Announcement on the Declaration Standards for Goods under Four Types of Measures in Special Customs Control Areas, Supervised Bonded Places, and Off-Site Processing Trade), revising the documentation requirements for processing trade manuals (ledgers) and bonded verification lists under these measures. The key updates are as follows:
I. Background
On May 9, 2025, the GACC, in collaboration with the National Development and Reform Commission, the Ministry of Finance, the Ministry of Agriculture and Rural Affairs, the Ministry of Commerce, and the State Taxation Administration, jointly issued Announcement No. 83 [2025] (Announcement on Adjusting Management Measures for Special Customs Control Areas, Bonded Supervision Sites, and Processing Trade Outside Designated Zones), specifying the regulatory requirements for four categories of goods.
To standardize the management of the four categories of regulated goods, the GACC has updated the relevant processing trade and bonded supervision systems. It also issued Announcement No. 116 [2025] (Announcement on Declaration Standards for Goods under Four Types of Measures in Special Customs Control Areas, Supervised Bonded Places, and Off-Site Processing Trade), clarifying the required documentation standards and management protocols.
II. Documentation Specifications for Special Manuals (Ledgers)
(I) Which operations require the use of special manuals/ledgers?
Enterprises utilizing four categories of bonded imported goods from overseas, unprocessed goods transferred from other special manuals/ledgers, and their processed finished products for processing trade, bonded logistics, bonded maintenance, bonded R&D, cross-border e-commerce bonded imports, or other bonded operations shall establish dedicated manuals/ledgers in the Golden Customs Phase II Bonded Supervision System (including B/C manuals and E, L, TW, TG, TH, H ledgers). No dedicated manuals/ledgers are required for commissioned processing ledgers, non-valued equipment manuals, or zone equipment manuals.
(II) Key differences between dedicated and regular manuals/ledgers:
1. A "Key Identifier" field has been added to the manual/ledger header. This field displays "1" for dedicated manuals/ledgers and remains blank for regular ones. Modifications to this field are prohibited.
2. A "Source Identifier" column has been added to the materials table of manuals/ledgers. For materials in special manuals/ledgers, enter codes 1, 2, 3, or 4 based on their origin; leave blank for ordinary manuals/ledgers. Modifications to this field are prohibited. This column remains blank in the finished products table. The following explains how to complete the "Source Identification" field in the materials section of special manuals/ledgers:
| Material "Source Identification" |
Abbreviation |
Category |
Remarks |
| 1 |
Key Overseas Materials |
Bonded materials either directly imported from overseas or transferred without processing, classified under the four regulated commodity categories. |
This includes: 1) Bonded materials under the four regulated categories directly imported from overseas; 2) Unprocessed bonded materials transferred from other special manuals/ledgers that fall under the four regulated categories. |
| 2 |
General Overseas Materials |
Bonded materials either directly imported from overseas or transferred without processing, not classified under the four regulated commodity categories. |
Includes: 1) Bonded materials directly imported from overseas that are not subject to the four categories of measures; 2) Unprocessed bonded materials transferred from other special manuals/ledgers that are not subject to the four categories of measures; 3) Bonded materials transferred from regular manuals/ledgers. |
| 3 |
Domestically procured materials and components |
Materials transferred from general trade exports outside domestic zones/sites or from finished products processed through regular manuals/ledgers. |
Includes: 1) Bonded goods exported into the zone/site through general trade declarations by enterprises outside domestic zones/sites; 2) Processed bonded finished products transferred from regular manuals/ledgers. |
| 4 |
Materials transferred from finished products in special ledgers |
Materials transferred from finished products processed through other special manuals/ledgers. |
Processed bonded finished products transferred from other special manuals/ledgers. |
3. The "Country (Region) of Origin" field for materials and finished products under the special manual/ledger must be completed in accordance with the non-preferential rules of origin. Items from different countries (regions) of origin shall not be consolidated.
III. Guidelines for Completing the Bonded Verification and Endorsement List for Special Manuals/Ledgers
(1) "Source Identification" and "Country (Region) of Origin" fields.
A "Source Identification" field has been added to the verification list for items under the special manuals/ledgers. The "Source Identification" and "Country (Region) of Origin" in the verification list must match those recorded in the special manuals/ledgers. Items with inconsistent "Source Identification" or "Country (Region) of Origin" shall not be consolidated under the same commodity item in the customs declaration form (filing list).
(II) Guidelines for reporting bonded transfers
Bonded transfers include: processing trade deep processing carry-over, bonded goods transfers between domestic areas (locations) and bonded zones, bonded goods transfers within and between bonded zones (locations), and surplus material carry-over. The relevant reporting requirements are as follows:
| Outbound Transfer |
Inbound Transfer |
||||
| Special Manual/Ledger |
Regular Manual/Ledger |
||||
| Raw Materials |
Finished Goods |
Raw Materials |
Finished Goods |
||
| Special Manual/Ledger |
Raw Materials |
One-to-one matching with mutual agreement |
Outbound Transfer must be type 4 |
Outbound Transfer must be type 2 or 3 |
Outbound Transfer must be type 3 |
| Finished Goods |
Inbound Transfer must be type 4 |
x |
Order Rejection |
x |
|
| Regular Manual/Ledger |
Raw Materials |
Inbound Transfer must be type 2 |
x |
As per current regulations |
x |
| Finished Goods |
Inbound Transfer must be type 3 |
x |
As per current regulations |
x |
|
(III) Domestic sales reporting specifications
Unprocessed goods imported under four special measures may be sold domestically. Finished goods processed from bonded imported materials under four special measures may be sold domestically if no bonded circulation occurred. Domestic sales reporting requirements are as follows:
| Operation |
Enterprise Category |
Management Requirements |
Verification List Entry Type |
| Domestic Sales of Finished Goods |
Enterprises in Comprehensive Bonded Zones/Bonded Port Areas (excluding VAT general taxpayer pilot enterprises) and Zhuhai-Macao Cross-border Industrial Park enterprises |
Tariffs levied on raw materials; import-stage VAT and consumption tax levied on finished goods. |
Declare the verification and endorsement list for "selective tariff collection" or "batch delivery with centralized customs declaration under selective taxation". |
| Pilot enterprises with general VAT taxpayer status in Comprehensive Bonded Zones and bonded port areas |
Tariffs, import VAT, and consumption tax shall be levied based on the materials. |
Declare the verification list for "domestic sales of finished products under single taxation". |
|
| FTZ enterprises (using exclusively imported materials and involving four categories of regulated goods) |
Tariffs shall be levied based on materials, while VAT and consumption tax shall be levied based on finished products. |
Declare the verification and endorsement list for "selective tariff collection" or "batch delivery with centralized customs declaration under selective taxation". |
|
| FTZ enterprises (partially using imported materials and involving four categories of regulated goods) |
Import duties, VAT, and consumption tax shall be levied based on materials. |
Declare the verification list for "domestic sales of processed materials in bonded areas". |
|
| Domestic sales of materials |
All enterprises |
Taxation based on materials |
Standard verification list |
IV. Filing Specifications for Simple Processing Operations of Logistics Enterprises
For logistics account books in special customs control areas and supervised bonded places involving four types of measures, simple processing operations that alter commodity codes or countries of origin are prohibited. The commodity codes and countries of origin for bonded finished products declared in simple processing operations must match those of their corresponding bonded raw materials.
V. Key Issues Regarding Bonded Goods Management
(I) Management requirements for production scraps, defective products, and by-products
Under special manuals/ledgers, production scraps, defective products, and by-products resulting from processing of commodities subject to four types of measures and their semi-finished products shall be either re-exported or destroyed. Specific provisions are as follows:
Production scraps, defective products, and by-products derived from bonded materials with source codes "1" or "4" may not be sold domestically, but may be re-exported or destroyed in compliance with existing regulations.
If an enterprise can separately manage the leftover materials, defective products, and by-products generated from processing bonded materials "1", "4" and "2", "3", then the leftover materials, defective products, and by-products from processing bonded materials "2" and "3" may undergo domestic sales procedures.
[Important Notes] The aforementioned two categories of leftover materials, defective products, and by-products must be managed separately. If separate management is not feasible, it is recommended that the enterprise either re-export or destroy all such materials.
(II) How to process the destruction and disposal procedures?
Enterprises applying for the destruction and disposal of leftover materials, surplus materials, defective products, by-products, or disaster-affected bonded goods under special manuals/ledgers must accurately declare the income derived from such destruction to the Customs. They shall complete taxation procedures as required and note in the remarks column: "Taxation on income from the destruction of special ledger items."
[Note] If there is income generated from the destruction of the aforementioned bonded goods, processing trade enterprises must declare a "Subsequent Tax Payment (Code 9700)" verification list and submit the corresponding customs declaration form.
(III) If the raw materials are not classified as Category IV controlled goods, but the processed finished products fall under Category IV, how should the procedures be handled?
For processing trade involving imported bonded materials that are not classified as Category IV controlled goods but yield finished products that do fall under Category IV, such operations shall be managed under regular manuals/ledgers. When these products are sold domestically, import duties shall be levied based on their actual condition.
[Important Notes] For enterprises within special customs control areas selling goods domestically outside the zone, the following procedures apply: First, non-first-nomination enterprises must declare goods according to their final inspection status and may not use the "Selective Tariff Collection" or "Selective Taxation with Batch Delivery and Centralized Customs Declaration" types in their verification lists. Second, if the finished products processed by a taxpayer enterprise are not directly exported overseas, they may only be exported to special customs control areas with tax refund functions (excluding pilot enterprises with general VAT taxpayer qualifications in this zone or other zones) and supervised bonded places.
Domestic sales by enterprises outside the zone shall be processed in accordance with current regulations.
VI. Management Requirements for Four Categories of Goods Imported Prior to the Implementation of this Announcement
(I) Goods that have been marked with control identifiers in the processing trade manuals/ledgers.
Sugar. For sugar manuals/ledgers established in compliance with GACC Announcement No. 50 [2024] (Announcement on Adjusting the Declaration Specifications for Sugar in Special Customs Control Areas and Processing Trade Outside the Zones), if continued implementation is required, the [M] mark must be indicated in the remarks column. Sugar entered into processing trade manuals/ledgers before June 10 may continue to be processed under the original manuals/ledgers.
Goods subject to additional tariffs imposed since 2025. For goods already recorded in processing trade manuals/ledgers before June 10 that are subject to additional tariffs as specified in the 2025 Tariff Commission announcement, implementation shall generally continue under the original manuals/ledgers.
For the above two categories of goods, enterprises may apply to the competent customs authority as needed to transfer them to their dedicated manuals/ledgers for continued processing.
[Important Notes] 1) The material source designation for transfers to dedicated manuals/ledgers must be marked as "1" (key overseas materials). 2) Surplus material carry-over declarations are prohibited; adjustments must be processed through verification lists for quantity increases/decreases.
(II) Four categories of controlled goods already recorded in logistics ledgers.
For the four categories of controlled goods recorded in logistics ledgers before June 10, implementation may continue under existing bonded policies after June 10.
(III) Other tariff-quota managed goods and trade remedy goods already recorded in manuals/ledgers.
For tariff quota-regulated commodities such as wheat, corn, rice, cotton, wool, wool tops, and fertilizers, as well as goods subject to trade remedy measures, which were already included in processing trade manuals/ledgers before June 10, they may continue to be processed under the original manuals/ledgers until completion.
(Contributed by: Audit Department, Guangzhou Customs, Shenzhen Customs, Nanjing Customs)
Disclaimer：The above content is translated from Chinese version of GACC. The GACC version shall prevail.
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