Spare Parts Replacement Attaining Trade Compliance with China Customs Regulations and Efficient Operating Performance Operating Environment • • • • • • • A multitude of choices exist in terms of which type of operation should be used to support a forwarded inventory of bonded spare parts i.e. Technical Service Station, Logistics Warehouse, Free Trade Zone Warehouse or Bonded Repair Enterprise. Each of the above has different advantages and disadvantages from a customs, tax, foreign exchange and operational efficiency point of view. Duty-paid spare parts replacement can attract scrutiny from in-charge Customs in terms of the dutiable value and therefore customs duty and import VAT liability. Complex Automatic Import Licensing, Commodity Inspection and CCC requirements may be applicable, depending on the HS Code of the spare parts, which can impact cycle times. Successful duty-exempt spare parts replacement requires complex tracking and reconciliation both in terms of documentation and inventory. There is a tightening of supervision and control by China Customs through more frequent and intensive post-importation audits and investigations. Financial penalties and temporary operational delays can arise in the event of non-compliance. Services and Solutions • • • • • • • • • Conduct a Feasibility Study to validate or assist with your choice of the preferred bonded operating model from a customs, tax, foreign exchange and operational efficiency perspective. Obtain advance valuation rulings from Customs to confirm the correct dutiable value of spare parts. Validate the correct HS Code for the spare parts with reference to the applicable customs duty rate, automatic import licensing, commodity inspection and CCC requirements. Seek exemptions from certain rules, such as CCC, so that operations may run more efficiently. Optimise the customs duty savings for duty-exempt spare parts replacement. Optimise the use of Free Trade Agreements to lower customs duties for duty-paid spare parts replacement. Design and implement trade compliance systems, procedures and operating manuals. Conduct Customs training for your import/export, logistics, and supply chain managers. Our former government officials can support you at meetings with Customs, AQSIQ or MOFTEC in order to assist in resolving any disputes. Worldtrade Management Services Worldtrade Management Services (WMS) is the customs and international trade advisory practice of PricewaterhouseCoopers. We have specialist teams in Hong Kong and Taiwan as well as teams in several main locations throughout Mainland China (Beijing, Tianjin, Dalian, Shanghai, Guangzhou and Shenzhen). Our practice is comprised of specialists drawn from a variety of backgrounds, including ex-senior customs officers (both local and expatriate) with international experience, international trade lawyers, accountants, and individuals from the private sector who have experience in logistics, customs and trade. Our former senior China Customs officials worked in locations such as Beijing, Shanghai and Shenzhen and have experience in the key areas of import processing, audits/investigations, valuation and tariff classification. We also have people that have specialist experience and knowledge of unique trading environments, such as the Waigaoqiao Free Trade Zone. Our local knowledge is combined with international expatriate expertise to create a rich pool of skill and experience. These factors combined allow us to draw on a depth of experience, technical expertise and relationships that are unavailable to many companies and other customs and trade practices alike. The China team is part of a regional practice, which was originally formed in 1992. The regional team now consists of approximately 80 full-time advisors through Asia-Pacific. Contact Details John Robinson - Partner john.p.robinson@cn.pwc.com Colbert Lam - Partner colbert.ky.lam@hk.pwc.com Beijing/Tianjin/Dalian Greg Nichols - Senior Manager gregory.nichols@cn.pwc.com Shanghai/Suzhou/Wuxi Damon Paling - Director damon.ross.paling@cn.pwc.com Johnson Zhuang - Manager johnson.zhuang@cn.pwc.com Shenzhen/Guangzhou Susan Ju - Senior Manager susan.ju@cn.pwc.com Authen Xiao - Manager authen.xiao@cn.pwc.com Tian Ying Chuan - Manager ying.chuan.tian@hk.pwc.com © 2007 PricewaterhouseCoopers. All rights reserved. “PricewaterhouseCoopers” refers to the China firm of PricewaterhouseCoopers or, as the context requires, the network of member firms of PricewaterhouseCoopers International Limited, each of which is a separate and independent legal entity.