When export goods are declared to enter a comprehensive bonded zone, the core of the declaration by the production and sales unit depends on the ownership of the goods and the identification of the responsible party.

The comprehensive bonded zone possesses the special regulatory attribute of being within the country but outside the customs territory. When we fill in the form, the core principle for determining the production and sales unit is to identify the domestic enterprise that holds the ownership of the goods, and use this as the basis for reporting.

⚠ Important reminder: Customs declaration with dual header is a compliant declaration mode

In actual business operations, it is often the case that the domestic shipper is not the same as the production and sales unit, which is commonly referred to in the industry as double-header customs declaration. This is a normal declaration method explicitly recognized and allowed by customs.

The core criterion for reporting is quite clear: the entity that is the final producer of the batch of exported goods within the country shall be reported as the production and sales unit on the customs declaration form.

The entire set of reporting rules is strictly implemented in accordance with the "Customs Declaration Form Filling Standards for Import and Export Goods of the People's Republic of China" (Announcement No. 60 of the General Administration of Customs, 2018). All declarations must be filled in strictly according to the standards.

In practical business scenarios, standardized reporting can be conducted according to two situations:

If the domestic manufacturer possesses the export operation rights and directly exports the goods to the comprehensive bonded zone, then both the production and sales unit and the domestic shipper can be the same manufacturer, as long as the information filled in by both parties remains consistent.

If the domestic manufacturer does not handle customs clearance themselves and entrusts a foreign trade agency to handle the export procedures to the comprehensive bonded zone, the production and sales unit must still declare the actual manufacturer itself, while the domestic shipper must declare the foreign trade agency entrusted to handle the export business.