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Customs Affairs Interpretation | The dividends of proactive disclosure in customs inspection-related fields have been upgraded again!

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Tianjin Inspection Says 'Penalty' (10) Detailed explanation of the proactive disclosure policy in the field of customs inspection and quarantine


Preface

On September 28, 2025, the 'Announcement of the General Administration of Customs on Handling Matters Related to Voluntary Disclosure of Violations' (General Administration of Customs Announcement No. 194 of 2025) (hereinafter referred to as Announcement No. 194) was officially released and will be valid from October 11, 2025 to June 30, 2027. The announcement stipulates that if import and export enterprises and units proactively disclose violations of customs regulations before customs discovers them and correct them in a timely manner, relevant preferential policies may be applied. This article focuses on the interpretation of the proactive disclosure policy in the field of customs inspection and quarantine involved in the announcement.


PART1 Exemption from penalties for voluntary disclosure of violations in the field of inspection and quarantine

Announcement No. 194 adjusts the penalty exemption rules for proactive disclosure of customs inspection and quarantine (inspection-related) violations, unifying and clarifying the exemption conditions for violations in the field of inspection and quarantine. Compared with the strict restrictions on the six types of inspection and quarantine violations listed in Annex 1 of Announcement No. 127 of 2023 of the General Administration of Customs (hereinafter referred to as Announcement No. 127), Announcement No. 194 provides more specific regulations on the exemption of penalties for enterprises involved in inspections. standards, and are consistent with the policy requirements of the 'Announcement of the General Administration of Customs on Revising the Customs Administrative Punishment Discretionary Standards of the People's Republic of China (2)' issued on February 19, 2025 (General Administration of Customs Announcement No. 21 of 2025). Five specific behaviors that are exempt from penalties for voluntary disclosure are clearly stipulated:

  1. Incoming grain does not record information such as receiving and unloading, transportation, storage, processing, scrap processing, and shipping directions as required.

  2. Failure to record and preserve business files of imported edible aquatic animals in accordance with regulations.

  3. Bamboo, wood and grass products leaving the country are not subject to inspection.

  4. The inspection declaration for outbound bamboo, wood and straw products is inconsistent with the actual situation.

  5. Inbound goods are packaged in wood and have not been inspected.


Things to note

1. The above five behaviors must meet all the following conditions at the same time to be exempted from punishment:

(1) Import and export enterprises and units can handle customs procedures in a timely manner;

(2) No harmful consequences were caused;

(3) The value of the goods is less than 500,000 yuan or the goods are subject to a warning or a maximum fine of less than 30,000 yuan according to laws, administrative regulations, and customs rules.

2. Inspection and quarantine violations involving safety, environmental protection, and sanitation matters are not subject to the scope of exemption from penalties for voluntary disclosure.

3. The 'same violation of customs regulations' is defined (behaviors of the same nature and violations of the same legal provisions and provisions of the same paragraph), and stipulates that the penalty exemption policy will not be applied to the second or more voluntary disclosures to the customs for the same behavior within one year (12 consecutive months).


PART2 Comparison of the old and new proactive disclosure policies in the field of inspection and quarantine

Compared with the original Announcement No. 127, the scope of non-penalty for voluntary disclosure of inspection-related cases has been greatly adjusted, and the overall trend has become more relaxed. At the same time, the policy that proactive disclosure and fines of less than 1 million are not included in the determination of corporate credit status continues.


New Announcement No. 194Original Announcement No. 127
If import and export enterprises and units proactively disclose the following violations of customs inspection and quarantine business regulations, and can handle customs procedures in a timely manner without causing harmful consequences, and the value of the goods is less than 500,000 yuan , or if the law, administrative regulations, or customs rules require a warning or a maximum fine of less than 30,000 yuan , no administrative penalty will be imposed.Import and export enterprises and units violate customs inspection and quarantine regulations and can handle customs procedures in a timely manner without causing harmful consequences.
Incoming grain does not record information such as receiving and unloading, transportation, storage, processing, scrap processing, and shipping directions as required.
Lifting imported food away from places designated or recognized by the customs without permission from the customs shall meet the following circumstances at the same time:
1. The lifted food has passed inspection and quarantine;
2. The illegal food has not been sold or used.
Failure to record and preserve business files of imported edible aquatic animals in accordance with regulations.
Exports of food produced by unregistered export food production enterprises shall meet the following conditions at the same time:
1. The food comes from domestic food production license enterprises;
2. Food production enterprises complete the registration process before voluntary disclosure;
3. The value of illegal food is less than RMB 10,000.

If the export food produced by an export food production enterprise fails to use raw materials from registered cultivation or breeding farms in accordance with regulations, the following conditions shall be met at the same time:

1. There are no quality and safety issues with the food;
2. No food safety incidents occurred;

3. Not notified by the overseas competent authority;

4. The value of illegal food is less than RMB 10,000.

Bamboo, wood and grass products leaving the country are not subject to inspection.

Bamboo, wood and straw products leaving the country without reporting for inspection shall meet the following conditions at the same time:

1. The illegal bamboo, wood and straw products have not yet been actually exported;

2. Illegal bamboo, wood and grass products can complete supplementary inspection and quarantine;

3. The illegal bamboo, wood and grass products have passed inspection and quarantine.

The inspection declaration for outbound bamboo, wood and straw products is inconsistent with the actual situation.If the inspection application for outbound bamboo, wood and straw products is inconsistent with the actual situation, the following conditions should be met at the same time:
1. The illegal bamboo, wood and grass products have not yet been actually exported;
2. Illegal bamboo, wood and grass products can complete supplementary inspection and quarantine;
3. The illegal bamboo, wood and grass products have passed inspection and quarantine.
Inbound goods are packaged in wood and have not been inspected.

If inspection agency companies, entry-exit express delivery companies, or inspection personnel fail to conduct reasonable reviews or are negligent in their work, leading to fraudulent certificates, the following circumstances must be met at the same time:

1. The certificate involved has not been used yet;
2. Take the initiative to return the certificate to the customs.

Any act of voluntary disclosure by an import or export enterprise or unit that is subject to a warning or a fine of less than 1 million yuan by the customs will not be included in the records of the customs' determination of the credit status of the enterprise. If a high-level certified enterprise proactively discloses violations of customs regulations, the customs will not suspend the application of corresponding management measures to the enterprise during the investigation. However, inspection and quarantine matters involving safety, environmental protection, and hygiene are excluded.Any act of voluntary disclosure by an import or export enterprise or unit that is subject to a warning or a fine of less than 1 million yuan by the customs will not be included in the records of the customs' determination of the credit status of the enterprise. If a high-level certified enterprise proactively discloses violations of customs regulations, the customs will not suspend the application of corresponding management measures to the enterprise during the investigation. However, inspections involving safety, environmental protection, and health matters are excluded.
This announcement is valid from October 11, 2025 to June 30, 2027.This announcement is valid from October 11, 2023 to October 10, 2025.


PART3 Compliance suggestions for enterprises

Establish and improve a self-inspection mechanism: Enterprises should regularly conduct comprehensive self-inspections on inspection and quarantine-related business, including declaration information of goods, implementation of inspection and quarantine requirements, etc., and promptly discover possible violations.

Strengthen policy learning and training: Keep abreast of the specific requirements and changes in the proactive disclosure policy in the field of customs inspection and quarantine, organize relevant personnel to conduct training, and improve employees' understanding and application ability of the policy.

Standardize the proactive disclosure process: Once possible violations are discovered, companies should promptly proactively disclose to the customs in accordance with the prescribed procedures to ensure that the materials submitted are true, accurate, and complete.

Focus on long-term compliance construction: Make proactive disclosure a part of corporate compliance management, improve the overall compliance level of the company by continuously improving internal management mechanisms, and reduce the occurrence of violations from the source.


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