Meet the Speaker of China Import Compliance: Zhao Jun

Zhao Jun

Senior Advisor

Bryan Cave International Consulting LLC


Tell us about yourself:

I was born in Shanghai and graduated from Shanghai University of Science & Technology in Mechanical Engineering in 1980. Prior to becoming a Customs official, I served for a state owned research institute as an engineer. I like being active in my spare time, such as traveling, hiking, visiting natural wonders at home and abroad and jogging 4 kilometers every morning. I also enjoyed listening to classical music when reading at home.

Tell us what a day is like in your field:

Every day is different. I generally do research and study new laws or regulations on a few websites, such as the General Administration of Customs, China Administration of  Inspection and Quarantine, State Administration of Foreign Exchange and Ministry of Commerce. I participate in a number of seminars to discuss hot topics or technic problems with peers, deliver training to our clients and offer professional advices to their questions. I am often involved in internal discussion with my team and give them assistance and guidance. Also, I assist or represent clients in approaching China Customs or other authorities on various across-border trade issues

 Tell us what you like about working at your company:

 The consulting professionals at Bryan Cave International Consulting (BCIC) have earned a Band 1/top-tier ranking by two publications, Chambers Global and Chambers Asia Pacific in the 2013 editions. BCIC earned recognition for work in international trade and World Trade Organization regulations for the Asia Pacific region. We provide strategic, cross-border supply chain, operational and regulatory consulting solution. Our professionals have many years of practical experience advising clients on WTO/FTA compliance and opportunities, customs compliance, audits, classification, valuation, transfer pricing, duty drawback, country of origin, free trade agreement and other preferential tariff schemes, as well as export control and anti-illicit trade.

The firm operates in more than 20 jurisdictions in the Asia Pacific region. I like working with the team and have a sense of achievements.

Tell us what you would change in the industry:

China Customs have stipulated regulations for cross-border transactions in most cases, but there are also times when there are no implementation rules in place. For example, a product may be classified under different HS headings by different Customs authorities and the same issue could have different results across different regions. Although we are able to help clients negotiate with the Customs from technical perspective, I think the key here is to address the issue at root. We proactively work with Shanghai American Chamber of Commerce and European Union Chamber of Commerce in Shanghai as well as other institutions to propose suggestions to Customs at various levels for improvement and subsequently deliver the message to the General Administration of Customs.

Give us one tip/best practice:

In cross-border transactions, HS code is a primary element for Customs declaration which results in different import tariff rates. This means a difference in the duty and value-added tax the Customs is able to collect.  Although the first 6 digits of HS code should be the same among WTO members based on WCO rules, different HS codes may still be applied to the same product by different suppliers and Customs authorities due to different experience and knowledge. Companies in US and EU hold the view that the parts of an equipment shall be classified under the same heading as the equipment while China Customs considers that parts and components, if imported in separate shipments, shall be classified under headings which provide the most specific descriptions.

Most multi-national companies pay corporate service fees or goodwill fees to their parent companies. Whether or not such fees contain royalties or assist fees related to import duty is a key focus of the Customs. If companies cannot provide to the Customs data needed to fully justify these payments, it is very likely that they will provoke Customs challenge or even anti-smuggling investigation.

These issues will bring significant risks to enterprises and could have adverse impact on to their operation and reputation.

Import Compliance

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