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CBEC: an advantageous way to enter the Chinese market

Cross-border e-commerce (CBEC) allows you to sell your products in the Chinese market without having to set up a legal entity in the country. With Notice n. 486 of November 28, 2018 (issued jointly by Development Reform Commission; Ministry of Finance; General Administration of Customs; General Bureau of Taxation; State Administration of Market Regulation) it has been clarified that for those products imported through the CBEC channel, the transaction is deemed as import of commodity for personal use, so no requirement for licensing, registering or other regulatory authorization for first-imported goods shall apply.

In order to take advantage of the CBEC benefits, the products sold must be included in a positive list approved by the Chinese government, which is updated regularly. This List currently includes 1,321 categories of products classified by HS codes.

The incentives reserved for the products on the Positive List covered by CBEC consist of:

1.Tariff exemptions for import-export

2.Sales tax concessions (reduction of VAT, Consumption tax and others)

3.Logistics solutions for the sale of goods intended for the personal use of Chinese consumers and not for resale, such as the storage of goods in shared warehouses managed by ecommerce platforms (B2B2C) under the supervision of Chinese Customs. This solution allows for faster and more competitive transport of foreign goods to the homes of Chinese consumers. In fact, the goods temporarily stored in these special warehouses are considered "imported" only after the Chinese consumer has purchased them online on the ecommerce platform. Therefore customs duties and VAT are postponed at the time of purchase by the consumer.

4. Opening of pilot areas in China for the import and export of goods via CBEC.

These are divided into 2 categories:

A. The "comprehensive pilot zones for CBEC" dedicated to assisting Chinese companies operating in global ecommerce and export. The first pilot zone was opened in Hangzhou in 2015.

B. The “pilot cities for CBEC retail importation”, dedicated to the promotion of cross-border e-commerce of foreign products imported into China. An example of this type of pilot zone is that of Hainan Island.

With notice no. 8 of February 8, 2022, the Council of State established 27 new pilot areas in 27 Chinese cities including: Yangzhou, Taizhou, Zhenjiang, Jinhua, Ma’anshan, Jingdezhen, Zibo, Rizhao, Xiangyang, Chaozhou, Baoji, Ordos, Kashgar, Alashankou.

Avv. Lifang Dong and Avv. Chiara Civitelli

The content of this article does not constitute legal advice, but has an informative function. For tailor made legal advice, contact the firm by e-mail to: or by phone +39 06 916505710. © Dong & Partners International Law Firm, All rights reserved.

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