When customs says "Please supplement the declaration," how should foreign trade professionals respond?

With 20 years of experience in foreign trade import and export, I often compare customs supplementary declaration to a "make-up exam" on the path to customs clearance—it is neither a punishment nor a hassle, but rather an opportunity for companies to perfect their declarations. It's like when you miss filling out part of an answer sheet during an exam, and the examiner gives you a chance to complete it. Today, let me, this "seasoned examinee," guide you through a systematic understanding of this important customs procedure.

Under what circumstances is a "make-up exam" required?

According to General Administration of Customs Announcement No. 49 of 2009, supplementary declarations are required in the following three situations:

• A "make-up examination" requested by the Customs.When customs has doubts about price, commodity code, or origin, it will issue a supplementary declaration notice
• "Re-inspection" after cargo releaseCustoms may request supplementary materials when verifying released goods
• Voluntary "back payment" by enterprisesWhen companies discover incomplete declarations, they may voluntarily initiate supplementary declarations

I remember handling a case in 2015 involving the import of German equipment, where incomplete declaration of technical parameters required supplementary submission. After promptly providing detailed technical specifications, not only was the customs clearance successfully completed, but it also established trust with customs authorities. Consequently, the clearance speed for similar goods significantly improved in subsequent shipments.

New Rules for "Make-up Exams" in the Digital Era

With the deepening of customs paperless reforms, Announcement No. 42 of 2012 established the electronic process for supplementary declarations:

• Electronic instruction receiptCustoms sends supplementary declaration requirements via system
• 5-working-day deadlineUpon receiving instructions, electronic declaration must be completed within 5 working days
• Dual-track operationIn paperless mode, electronic declaration suffices; in paper mode, physical documents must still be submitted

Special reminder: After electronic supplementary declaration is approved, unless it's paperless clearance, two printed copies must still be submitted to customs with signatures and stamps. This is like signing a confirmation after submitting an electronic exam.

Tips for Handling Three Types of "Make-up Exam Subjects"

Price Supplement Declaration: Justify the Reasonableness of Your "Quotation"

When customs questions the declared value, a 'Supplementary Declaration Form for Price' must be completed. Key preparations:

• Complete price composition explanation (freight, insurance, etc.)
• Comparison of transaction prices for identical or similar goods
• Declaration of special relationships (e.g., affiliation between buyer and seller)

Supplementary Declaration for Commodity Classification: Clarify Your "Identification"

Commodity code disputes are common reasons for supplementary declaration. Key points to address:

• Provide detailed product manuals and pictures
• Attach authoritative classification opinions (such as advance ruling decisions)
• Explain classification basis (including reasons for excluding other codes)

Supplementary Declaration of Origin: Verifying Your "Pedigree"

Origin supplementary declarations often require:

• Submit supplementary certificates of origin (such as FORM A, ECFA certificates, etc.)
• Provide raw material procurement certificates
• Detailed description of processing procedures

A client once almost paid 5% extra tariff due to untimely submission of ASEAN Certificate of Origin. After timely supplementation, not only were overpaid taxes recovered, but an origin document management system was established.

The consequences of failing a "make-up exam"

If supplementary declaration cannot be completed within 5 working days, customs will:

• Determine based on existing informationFinished tax price., commodity codes and origin
• May result in higher tax burdens or administrative penalties
• Affect enterprise credit rating

More seriously, intentional false supplementary declarations may be identified as smuggling. Just like cheating in exams, the consequences are severe.

Professional advice: Turn "make-up exams" into a "bonus point opportunity."

Based on years of experience, I've summarized the following practical suggestions:

• Establish declaration review mechanism: Incustoms clearanceSystematically check price, classification, and origin information beforehand
• Improve document management system: Ensure quick access to documents required for supplementary declaration
• Utilize the pre-ruling system: Obtain in advance for complex commoditiesClassification of Customs, price determination
• Developing a professional team: Or entrust experienced customs brokers

Supplementary declaration is not a monster, but an important channel for communication between customs and enterprises. Handling it correctly can not only resolve current issues but also build trust with customs, paving the way for smoother clearance in the future. Remember, in the "big test" of import and export, supplementary declaration is an opportunity to correct mistakes, not a punishment.

If you have any questions about supplementary declarations, feel free to consult anytime. In my 20 years of foreign trade experience, I've seen too many cases of losing big for small gains, and have helped many enterprises establish clearance advantages through standardized declarations. Customs matters value professionalism and integrity most.