Deadlines of the Transition Policy on Cross-Border E-Commerce (B2C) Tax Policy

Updated on 17th Nov. 2016, by Susan

Since 8 April 2016, the new tax on Cross-border E-commerce of imported commodities at retail (B2C) (hereinafter refers to CBEC) has included customs duties, value added tax (VAT), and consumption tax.

At t he same time, 2 positive lists were issued. Only the listed commodities can be imported to China through CBEC.

In order to make relevant enterprises gradually adapt to the regulatory requirements, Chinese governments give 1 year transition period to the CBEC. Before 11 May 2017, the customs clearance form of online bonded commodities, and approved licenses of health food, infant formula milk powder and food for special medical purpose (FSMP) will not be required.

On 15 November 2016, China government agrees to further extend the transition to the end of 2017. With this, the deadlines on all food categories, including general food, infant food, health food, FSMP, delay until 31 December 2017. The relevant requirements will come into force on 1 January 2018.

Deadlines of the transition policy on special foods

S.N.	Required license	Deadline
1	Registration or filing certificate of health food	2017.12.31
2	Formula registration certificate of infant formula milk powder	2017.12.31
3	Formula registration certificate of FSMP	2017.12.31

After the deadline, the relevant certificates for these special foods through CBEC shall be provided. Otherwise, the import through CBEC will not be allowed as well.

Administrative measures on special foods issued by CFDA

S.N.	Name	Released date	Implemented date
1	Administrative Measure on Health Food Registration and Filing (Please kindly click here for detailed interpretation about this Measure)	2016.03.01	2016.07.01
2	Administrative Measures on Product Formula Registration of Infant Formula Milk Powder (Please kindly click here for detailed interpretation about this Measure)	2016.06.08	2016.10.01
3	Administrative Measures of FSMP Registration (trial) (Please kindly click here for detailed interpretation about this Measure)	2016.03.07	2016.07.01

CIRS Comments

Taking health food registration as an example, it will take a long time to apply for the registration. The requirements on the application dossier are very strict, enterprise shall arrange sample tests, prepare every material in accordance with the requirements. However, the transition period is short. When the period ends, there will be product vacancy in Chinese market.

The formal Measures for the health food registration and filling, FSMP registration, and infant formula milk powder registration have been published. Therefore, CIRS suggests that relevant enterprises have long-term plan to enter Chinese market shall start to consider the application, such as prepare some required materials, conduct product registration feasibility analysis, etc. It will shorten the application duration, and help enterprises to get the certificate more quickly.

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Reference:

Ministry of Finance talked about supervision management for retail importer in transition period

Specification on commodity notes in cross-border E-commerce imported commodity list

Specification on commodity notes in cross-border E-commerce imported commodity list (second batch)

Conversation on the extension of transition period in cross-border E-commerce imported commodity