My opinion on the reduction of customs clearance fee for import and export of containers by us $100

On September 26, premier li keqiang proposed at the executive meeting of the state council: "the compliance cost of container import and export within the year will be reduced by more than us $100 compared with last year, and the big coastal ports will be significantly reduced.

As a professional research institution in the field of trade facilitation, the "compliance cost" mentioned by the prime minister is also the object of concern and research. We hereby contribute our superficial opinions and opinions without any reserve, hoping to be helpful for the consideration and discussion of relevant issues.

Import and export link compliance costs this concept comes from the world bank's "doing business" report, "cross-border trade" as one of top ten indicators secondary index by the time (cost) and the costs of two parts, the cost is further divided into "border compliance costs (the cost of the complete customs clearance procedure) and compliance costs" documents "(the cost of the customs clearance documents).

Unfortunately, the bank has not clearly defined the connotation and extension of border compliance cost and document compliance cost, and the projects included can only be determined according to the roughly given scope, resulting in a serious deviation between the conclusions of the bank's report and the actual situation.

Four years ago, the center launched two research projects on customs clearance time and customs clearance fee at the same time.

Why?It's more complicated than I expected before I started the project. What's so complicated about it?Let me expand it a little bit.

1. Define the scope of customs clearance cost.The cost of completing the customs clearance process for a batch of goods is 70 or 80 items in total, which is not easy to determine.Such as port of shipment, in theory should be classified as customs clearance cost range, but the shipping costs involved in the transport distance, even the dock, also has a port yard and port outside the stack secondary container, the cost has the difference, if the simple use it as a different port customs clearance cost comparison between projects, it is not reasonable.

The following table is the research center according to:(2) direct collection of import and export enterprises or their agents;(3) the list of "routine fee items" defined by the three conditions of "arrival of cargo ship -- return of empty container to storage yard" for import/" booking confirmation -- departure of cargo ship "for export.

For the main body

Import charges

Export charges

Shipping company/agency

Terminal handling charges

Shipping company documentation fee

Shipping company replacement fee

Equipment handover fee

Container handling charges

EDI transfer fee

Terminal handling charges

Shipping company documentation fee

Seal fee

AMS/ENS/AFR, etc

Shipping agency booking fee

VGM handling fee

Equipment handover fee

Container handling charges

EDI transfer fee

Port charges

Declaration/inspection enterprises

Customs service charge

Inspection service fee

Customs service charge

Inspection service fee

terminal

Port charges for cargo

Port facility security fee

Tally fee

Port charges for cargo

Port facility security fee

yard

Yard clearance fee

Handling fees

Terminal charges

The maritime safety administration

The port of charge

The port of charge

2. Name of charging items.Even at home, different port charges related project name is not very standardized, content of the same charge, charge under different names, or, in turn, charging the same name, but different charge content, such as in previous years of electronic declaration data transmission, some port call information service charge, some port call data transfer fee, this would require the definition of each project and name according to the logic of "law of identity" requirements to each definition and specification.

3. There are a lot of factors influencing the charge.The fishbone diagram below provides a general picture of the impact factors that lead to the price difference of different items. If a scientific comparative study is to be carried out, it must first be scientifically regularized.

4. Numerous organizations.Involved in customs clearance process in addition to the customs (original and entry-exit inspection and quarantine departments), and shipping companies, ship generation, the consignee or consignor, freight forwarders, port operation unit, storage area, transport enterprises, tally departments, Banks, a single window and electronic payment operational institutions, inspection, sorting, fumigation/disinfection departments, customs clearance agent, quality appraisal unit, such as more than ten kind of effect of different subjects, mostly involves the charging problem, data of the research on information collection difficult.

5. The nature of charges is different.In addition to tariff, the current port charges can be divided into government pricing and government-guided pricing and market-regulated pricing, among which the market-regulated pricing can be further divided into fully competitive pricing and non-competitive or even monopolistic pricing.

6. Collection on behalf of others.Many charging items belong to the collection &payment, which the ship generation, freight charge particularly prominent, many or two or even three collection &payment, such as the THC (terminal operating costs), the first by the ship generation to replace the owner to freight charge, the second in the event that the payment is made by the forwarder on behalf of the owner if forwarder and customs agent for different subjects, also may happen again collection &payment, greatly increased the complexity of the research.

7. Different billing methods.Port charges, some are based on the number of cases, such as terminal operation fees, how much a box charge (which is also divided into large and small boxes), some are based on the number of bills (bill of lading), how much a bill charge, such as changing the bill, customs clearance, the need for the corresponding technical processing.

8. Occurrence probability and frequency of charges.Port customs clearance fee, some is almost every ticket to occur, such as the THC (terminal operating costs), and most of the charging items happen in a particular situation or for a specific commodity, and the frequency difference is very big, such as customs declaration, belongs to the high frequency fees, customs inspection, the costs of inspection and quarantine treatment occurred frequency is low, but will often encountered, and some particular commodity specific charges, fees for dangerous chemical goods, for example, there are many no port would not have taken place for business.

9. Change of charging items.For example, after the function of inspection and quarantine is incorporated into the customs, some companies cancel the charge item of inspection and quarantine declaration agency fee, and merge the original inspection and quarantine declaration agency fee into the corresponding customs declaration agency fee.

In another way, the following differences can be found after a survey of the cost of import container goods identified as customs inspection:

1) FCL or LCL?

2) number of containers. If there are several containers in a shipment, shall we check one or several of them?

3) large case or small case?

4) simple door inspection or half cut, side cut and full cut?

5) is there any problem with the inspection result?

6) is the tunneling fee to be paid by the enterprise or to be collected from the government or the import and export company according to the inspection results?

...

Port charges are so complex and multi-dimensional that many specific technical problems still need to be solved before the target of us $100 annual fee reduction proposed by the premier can be achieved:

1) subject of responsibility.Customs clearance fees involve many enterprises and institutions with different natuses. According to the current industrial management framework, the price and fees are charged by the national development and reform commission (NDRC).There are many international shipping enterprises, which domestic departments do not have administrative jurisdiction.Which department should carry out this task should be the first clear question.

2) determination of cardinality.Since a $100 reduction is proposed, a certain base of reduction is needed.The world bank's doing business 2018 assessment of China's import compliance costs is us $745. If we use this as a base, then we have more than us $100 to reduce the cost, even us $300 or us $400.But the bank's figure is so far out of line with reality that it makes no sense to use it as a base.

3) determination of fee reduction objects.The compliance cost of import and export of containers proposed by the premier is more than us $100 less than that of last year.If not, it needs to be further defined and clarified.

4) determine the scope of fee reduction.In my understanding, the reduction scope should be the "regular" cost that will be generated for each ticket as the main reduction scope, because the occasional non-regular charge, the reduction of 35,000 is also of no practical significance.But if it is a regular fee reduction, the current import and export goods per container costs $300 or so, to a third of a sudden, where to start?

5) selection and determination of means and methods of cost reduction.Administrative fees which belong to the government may be reduced or exempted at the discretion of the state.In recent three years, the government's administrative charging items, especially the original belong to the customs administrative fees, such as electronic data transfer fees, customs declaration fee, has been cancelled, the original part of inspection and quarantine fees to cancel or reduce the large range, also in conventional cost at present, only one, the port charge by each port according to the 64 yuan/box charge turned over to the department of transportation, even cancel only one over ten is $100, and the target gap is huge.But the charge of business service enterprise belongs to the market behavior, no matter adopting the average apportionment or designating the industry to reduce the charge, it goes against the legal concept and market principle.

Personal opinions and opinions:

1) we should give full recognition to the measures taken by relevant departments in the past few years to reduce the burden on enterprises and continuously improve the business environment, as well as the achievements they have made. We should also encourage and look forward to the new requirements put forward by the government this time.

2) even if there is a good purpose and goal, the method and means are more important. The first thing we should insist on is the awareness of "legal system".The state administration for industry and commerce administers farmers' markets. The content and scope of the administration are commodity quality, shortweight, and market manipulation.

3) organic unity of goals and means.If in order to reduce the market price level, improve people's well-being, industrial and commercial bureau forced farmers to sell three dollars of potatoes for a dollar, on the second day will be found in vegetable farmers all ran away, the end result is to put the vegetable farmers and residents both hurt, similar folly is not uncommon, may not happen in the customs clearance JiangFei.

4) as far as the current situation is concerned, the implementation possibility of this customs clearance fee reduction lies in a thorough investigation of the existing routine charges item by item.Based on my understanding of port charges over the years, I believe that the exchange fee, document fee and terminal handling fee collected by the ship should be the focus of the investigation.These items cost above is the international shipping companies to import and export enterprises or their agents, in the current $300 accounts for more than 50% of the total cost, mainly studies suggest it as object of the reason is that these items whether it's the necessary fees and even the whole link and charge standard is reasonable has a bigger question discussion space.For example, change a bill of lading into a bill of lading, the actual cost is only a few yuan and charge hundreds of yuan, what is the reason and basis?Document fee also is such, after all what document, a batch of goods should charge hundreds of yuan?Are these charges charged by the shipping company in other countries?At least as far as I know, the link of order replacement does not exist in the ports of the United States.These charges are rarely mentioned, the reason was that the shipping company in the supply chain of international trade unique strong position in almost all the import and export enterprises use it as a practice of course fee to receive, or even to question, but because the status of disparity, the lack of channels of communication, negotiation and ability, have been powerless.The government can and should do something about it.

This article is from the port circle