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A reminder of a hidden pitfall in compliance management, an easily missed link - exemption from 3C customs clearance does not mean completion! Standardized write-off is a complete closed loop of compliance

Views: 0     Author: Site Editor     Publish Time: 2026-09-04      Origin: Site

Foreword:

In daily import business and corporate customs compliance management, many companies consider that the business is over after completing the 3C exemption certificate and completing customs clearance and storage of goods. Over a long period of time, a large number of 3C-free unwritten accounts have accumulated in the enterprise system, which has become a compliance risk that is easily ignored.
As market supervision continues to strengthen, 3C-free business has already entered the stage of full-process closed-loop supervision. Successful customs clearance alone cannot avoid subsequent verification risks. Completing the write-off procedures in strict accordance with the requirements is the true compliance end of this business. Combining current laws, regulations and local implementation rules, the compliance points of the entire process of 3C exemption from application, import, use to verification are summarized as follows:


01 Strictly abide by laws and regulations and establish a solid bottom line of compliance

1. The legal hard bottom line
is clearly stipulated in the Certification and Accreditation Regulations of the People's Republic of China (revised in 2023). Products included in the compulsory product certification catalog without 3C certification are strictly prohibited from private import, domestic sales and commercial use. This is a common legal red line in the industry, and illegal use will face high administrative penalties.


2. The national unified implementation standards
refer to the National Municipal Supervision and Supervision Certification Letter [2019] No. 153. The document clearly delineates the scope of application of six legally exempted 3C businesses, which are also the only compliance basis for enterprises to apply for 3C exemption. They are scientific research and test samples, equipment maintenance parts, production line supporting parts, commercial display supplies, fully exported parts of assembled machines, and other statutory special-purpose products.


3. Local Refined Management Rules
Pu Shi Jian Gui [2024] No. 2 Implementation Rules are currently the most practical document with the strongest implementation. They make detailed provisions on the scope of use of 3C-exempt goods, time limit for write-off processing, goods destruction standards, retention of archived information, etc. It is also the main reference guideline for enterprises to carry out daily write-off work.


02 Compliance points for the whole process of 3C exemption


1. When companies submit applications for 3C exemption during the business application stage
, they must truthfully fill in the purpose of the goods in strict accordance with the statutory applicable scenarios, and fill in the content accurately and specifically. Do not fill in vague expressions such as self-use, spare, trial, etc. The declared purpose directly determines the subsequent write-off method. If the purpose is not filled out in a standardized way, it will directly lead to the failure of normal write-off in the later period and form long-term compliance issues.


2. During the formal import declaration process of goods during the import customs clearance stage
, the corresponding 3C exemption certificate number must be accurately bound to ensure that all documentary information such as the import customs declaration form, exemption certificate, product name, specification model, and import quantity are completely consistent. The unified and consistent document information is the basic prerequisite for the subsequent successful completion of write-off.


3. During the daily use control stage,
after the goods are put into storage and put into use, the company must do a good job in controlling the flow of goods and standardizing the internal collection process. It is strictly prohibited to give test samples to others at will, transfer exhibition exhibits internally at low prices, and discard or misappropriate surplus imported parts without permission. The destination of all goods exempt from 3C control must be clear and clear, and the entire process must be documented.


4. The smooth customs clearance of the goods at the core stage of business verification
only represents the completion of the import process, and the completion of compliance verification will mark the formal completion of the entire 3C-free business. At present, only three common write-off methods are recognized in China, and enterprises can handle them according to the actual use of the goods.

First, the write-off
method is applicable to equipment maintenance spare parts, production line supporting parts, production consumable parts and other goods that have been put into normal use. Enterprises should properly retain and archive internal receipts, equipment maintenance records, production line assembly ledgers and other relevant information.
According to the relevant provisions of the National and Municipal Supervision Certification Letter [2019] No. 153, the parts and components that are specially used to assemble the entire machine for export and import, the enterprise must complete the system write-off report within the agreed time after the finished product is exported. This requirement is an established compliance commitment when the enterprise applies for exemption and must be strictly implemented.

Second, return write-off
is applicable to 3C-free goods that have not been put into production, have idle test samples, and have no need to be retained after the exhibition. The write-off process can be completed by returning the goods overseas to the original route. When processing, be sure to keep the export customs declaration form for the corresponding batch of goods to ensure that the product information and quantity in the customs declaration document correspond to the original import data.

Third, destruction and write-off
is the most frequently used write-off method in the industry, and it is also the most prone to non-compliant operations. Most idle samples, surplus spare parts, and exhibition exhibits are handled this way.
According to the clear requirements of Pushi Supervisory Regulations [2024] No. 2 document, compliance destruction must be completely defunctionalized, completely losing the original use value of the product, and preventing the product from flowing into the domestic market again for circulation and sales. Enterprises need to keep complete photos of the destruction site with real-time timestamps, videos of the entire destruction process, and internal destruction execution ledgers, and clearly mark product models, batches of goods, execution personnel, and execution time. Simple operations such as damaging the appearance of the product and discarding it at will will not pass the official write-off review.
All business is handled online at http://cccmb.cnca.cn/login. The screenshots of the interface are as follows:

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03 Two hard red lines that companies must abide by:

1. Strictly control the overall write-off time limit
; 2. Ensure accurate and unified data across the entire chain.
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04 Current trends in industry supervision. At this

stage, market regulatory authorities have long bid farewell to the previous loose management model for 3C-free businesses, and have fully implemented a normalized supervision model of strict access, strict control, strong traceability, and mandatory write-off. Cross-regional collaborative verification mechanisms are implemented in many places. Once an enterprise commits violations such as failure to write off overdue materials, writing off false materials, or changing the use of goods without authorization, in addition to being fined 50,000 to 200,000 yuan and confiscating all illegal income in accordance with relevant regulations, it will also be included in the key market supervision list, which will directly affect the normal approval of all subsequent 3C-free businesses of the company.

05 Practical suggestions for internal compliance management of enterprises

1. Standardize the 3C-free business application process, fill in the usage of goods truthfully, and abandon the habit of general and vague filling in.
2. Establish an exclusive 3C-free goods management ledger for the enterprise, and ensure that dedicated personnel will follow up every ticket and file, and track the entire process until the write-off is completed.
3. Clarify the internal management system for the use of goods, and strictly prohibit illegal activities such as the private circulation, giving away, and disguised sales of 3C-free goods.
4. Plan the write-off processing time in advance, compile and complete relevant supporting materials in a timely manner as the write-off deadline approaches, and eliminate overdue backlogs of large-volume business.
5. Carry out cargo destruction work in strict accordance with official standards, and prepare image data and paper ledgers to ensure complete write-off data.
6. Regularly organize internal compliance self-examinations, comprehensively sort out and clean up historical unwritten accounts, and make rectifications in batches to resolve existing compliance risks.

06 Conclusion
The 3C exemption related policies are compliance and convenience measures to assist enterprises in production and operation and simplify the import process. They are by no means a gray channel for enterprises to avoid market supervision. In an environment of increasingly rigorous and perfect industry compliance supervision, taking chances and delaying will create major risks for corporate operations. Facing the importance of the 3C write-off exemption work, straightening out the problems left over from history without write-off, standardizing the whole-process management of new import business, implementing every compliance management detail, and guarding the bottom line of corporate customs compliance are the solid foundations for stable operations and long-term development of enterprises.

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