Letter to Editor - China Customs Trade Compliance Program - New Regulations Effective 1 April 2008

Sep 26, 2026

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Letter urging readers’ attention to newly announced China Customs regulations affecting the China Customs Trade Compliance Program. It explains the purpose of continued modernization, informed trade compliance, improved customs–trade partnership, and alignment with the WCO Framework. Key points include classifying importers of record and customs brokers into AA/A/B/C/D, eligibility for Class A and AA benefits, implementation rules, and guidance on selecting an active IOR to reduce compliance risks and costs.

LanguageEnglish

CategoryResearch & Report

FormatPDF

Pages2

Reading Time5 min

AccessFree to download

China Customs Trade Compliance Program - New Regulations

Purpose and effective date

Classification of importers of record (IORs) and brokers

Eligibility for Class A and Class AA IORs

Benefits granted to Class A and Class AA IORs

Implementation rules and standards

Guidance on being an active IOR in China

Dear Sir I wish to draw your readers’ attention to new regulations that affect China Customs’ Trade Compliance Program. The aims of the new regulations are to continue China Customs’ modernisation efforts, encourage informed trade compliance, improve customs-trade partnership, and implement the WCO Framework of Standards to Secure and Facilitate Global Trade. After consulting with the trade, China Customs Administration recently announced the new regulations concerning customs compliance and trade facilitation, to take effect from 1 April 2008. Brieﬂy, these regulations address: 1. Classiﬁcation of Importers of Record. In accordance with the regulations, based on the internal control level, business performance, compliance records, and other information, Customs will classify the importers of record (IORs) and customs brokers into categories of AA (AA Program), A, B, C, and D. While the IORs of Class B will be treated normally and the IORs of Classes C and D will receive no beneﬁts but more inspections and audits, the IORs of Classes A andAA will enjoy enormous beneﬁts of trade facilitation. 2. Eligibility, requirements and beneﬁts for IORs of Classes A and AA. To be qualiﬁed as a Class AIOR, the company shall,(1) submit an application to upgrade its class; (2) be the IOR registered with Customs; (3) be a Class B IOR for more than 12 months; (4) have no smuggling offence and activity, or other activities violating customs laws and regulations in the past 12 months; (5) have no activity of importing or exporting goods that infringe intellectual property rights in the past 12 months; (6) have no delay in payments of revenue to Customs in the past 12 months; (7) have imports and exports volume beyond US$500,000.00; (8) have customs entry errors lower than 3%; (9) have sound recordkeeping and accounting systems; (10) comply with laws, regulations and customs procedures; (11) submit an annual business management report to customs; (12) have no bad records with other government agencies such as Commerce, Central Bank, Tax, Industry and Business Administration, Commodity Quality Inspection, Foreign Exchange. The Class A IORs will receive trade facilitation beneﬁts from Customs in: (1) remote ﬁling and goods release at the port of entry; (2) customs inspection at the production site, if necessary; (3) privileged fast inspection and release; (4) advance customs entry before the goods arrive at the port of entry; (5) 24/7 urgent customs clearance; (5) waiver of customs bond or cash deposit requirement for processing a trade operation. To be qualiﬁed as a Class AA IOR, in addition to the requirements for the Class A IOR, the company must,(1) submit an application; (2) be a Class A IOR for more than 12 months; (3) have annual import and export volume beyond US$30 million; (4) pass the customs audit and veriﬁcation for the program and meet the internal control, trade compliance and security in trade requirements; (5) submit an annual ﬁnancial audit report, annual business management and internal control report, and biannual importexport business report. In addition to the beneﬁts for the Class AIOR, the Class AA IOR will receive extra beneﬁts in (1) trusted customs release; (2) a customs account manager coordinating customs and trade questions; (3) direct customs release after the entry passes the electronic review; and (4) waiver of cargo inspection under normal circumstances. A new IOR needs to start from a Class B IOR, and then apply to upgrade 12 months later. Since Customs brokers are also classiﬁed as AA, A, B, C, and D level, the importer of record must be very careful in selecting its customs broker and avoid hiring a customs broker below Class B. 3. Implementation rules and standards tobe deployed. With the announcement of the new regulations, China Customs is working on the implementation rules, standards and systems, such as Importer Compliance Assessment System, and Internal Control Standards. We understan

FAQs

What is the effective date and stated purpose of the new China Customs regulations?

The regulations take effect from 1 April 2008. They aim to continue modernization, encourage informed trade compliance, improve customs–trade partnership, and implement the WCO Framework of Standards to Secure and Facilitate Global Trade.

How are importers of record (IORs) and customs brokers classified under the new rules?

Customs classifies IORs and customs brokers into AA, A, B, C, and D based on internal control level, business performance, compliance records, and other information. Classes A and AA receive major trade facilitation benefits, while Classes C and D receive no benefits but face more inspections and audits.

What are key eligibility requirements for an IOR to qualify as Class AA?

Besides meeting Class A requirements, a company must apply for Class AA, hold Class A for more than 12 months, have annual import and export volume beyond US$30 million, pass customs audit and verification for the program, and submit the specified annual and biannual financial and business/internal control reports.

Sep 26, 2026

Upload by sagouaw