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China: Updated plan to promote comprehensive bonded zones

China: Updated to promote comprehensive bonded zones

China’s government announced plans to promote the “comprehensive bonded zone” (CBZ) regime.


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According to Circular (2019) No. 3 (25 January 2019) released by the State Council, development of CBZs will be promoted with respect to the following five centres:

  • Processing and manufacturing centres
  • Research, development and design centres
  • Logistics and distribution centres
  • Maintenance and repair centres
  • Sales and service centres

Expanded CBZ measures

Circular (2019) No. 3 provides details of 21 implementation measures, including: 

  • All companies in CBZs will be granted and allowed to qualify for the status as “VAT general” taxpayers.
  • All companies in CBZs may be engaged as “toll manufacturers” by companies located in China.
  • Import licenses for domestic sales of cellphones and auto parts processed in a CBZ will be exempted.
  • Consumables imported for research and development (R&D) activities may be imported under bonded status and reconciled upon “faithful declarations” (hence, customs duties will be exempted with certain conditions).
  • Automobiles will be allowed to be imported into CBZs for bonded storage and exhibition.
  • Companies in CBZs will be encouraged to perform global maintenance as well as re-manufacturing activities with high technology and high added value.
  • There will be a greater flexible supervision mechanism provided with respect to leased airplanes.
  • There will be full expansion of cross-border e-commerce regimes in CBZs.

Certain of these measures previously were already operating as pilot programs. These measures now will apply for all companies in CBZs.  

This promotion of the CBZ regime involves 14 government authorities (including customs, the tax authorities, and foreign exchange administration).   

KPMG observation

Trade professionals have observed that the trend in China is for other forms of customs special supervision areas (e.g., export processing zones, bonded zones, bonded ports) to be gradually upgraded to CBZs, thus affording companies in customs special supervision areas greater access to more preferential regimes. There may be benefits under the CBZ regime, for instance, with respect to a U.S. company considering plans to establish itself in China for purposes of manufacturing, trade or R&D activities. 

For more information, contact a KPMG trade and customs professional in China:

Rachel Tao | +86 21 2212 3473 | 

Or to learn more about KPMG’s Trade & Customs Services, contact:

Doug Zuvich
Partner, Global Practice Leader
T: 312-665-1022

Andy Siciliano
Partner, National Practice Leader
T: 631-425-6057

Irina Vaysfeld
T: 212-872-2973

Robert Waldrop
T: 212-954-8117 

Christopher Young
T: 312-665-3229

George Zaharatos
T: 404-222-3292

John L. McLoughlin
Principal, East Coast Leader
T: 267-256-2614

Luis (Lou) Abad
Principal, WNT
T: 212-954-3094

Amie Ahanchian
Managing Director
T: 202-533-3247

Gisele Belotto
Managing Director
T: 305-913-2779

Andy Doornaert
Managing Director
T: 313-230-3080

Jessica Libby
Managing Director
T: 612-305-5533

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