2018上海美国商会贸易环境满意度调查报告.pdf

Trade Facilitation Taskforce Survey Report 上海美国商会贸易环境 满意度调查报告About The American Chamber of Commerce in Shanghai The American Chamber of Commerce in Shanghai (AmCham Shanghai), known as the “Voice of American Business” in China, is one of the largest American Chambers in the Asia-Pacific region. Founded in 1915, AmCham Shanghai was the third American Chamber established outside the United States. As a non-profit, non-partisan business organization, AmCham Shanghai is committed to the principles of free trade, open markets, private enterprise and the unrestricted flow of information. About AmCham Shanghais Trade Facilitation Taskforce (TFT) AmCham Shanghais Trade Facilitation Taskforce engages Shanghai Customs (Customs) and the China Inspection and Quarantine Services (CIQ) regularly on key issues related to import and export business. In March 2007, the Chamber launched the Customs Taskforce to improve communications between AmCham Shanghai members and Shanghai Customs. In 2012, the Taskforce was renamed the “Trade Facilitation Taskforce“ because of the inclusion of CIQ. Each year, AmCham Shanghai invites companies from the manufacturing, logistics and trade sectors to participate in the “Trade Environment Satisfaction Survey.” 关于上海美国商会 上海美国商会被称为在华“美国商业之声”，是亚 太地区规模最大的美国 商会之一。商会成立于1915 年，是第三家设立于美国境外的美国商会。作为一家 非盈利性、中立的商业组织，上海美国商会致力于自 由贸易政策，市场开放，私有企业和信息的自由流 通。 上海美国商会的使命是努力通过提供高质量的 商务信息与服务，政策游说支持及丰富的商业联系与 交流，为会员的成功经营以及美中商贸关系的增进提 供支持与帮助。 关于上海美国商会贸易便利化工作组 上海美国商会贸易便利化工作组就进出口业务相关问 题与上海海关和中国检验检疫局定期接洽。2007年3 月，上海美国商会成立海关工作组，旨在改善上海美 国商会会员与上海海关之间的沟通。2012年，工作 组更名为“贸易便利 化工作组”，将检验检疫业务 囊括在内。上海美国商会每年都会邀请制造、物流和 贸易领域的企业参加“贸易环境满意度调查”。 2AmChAm ShAnghAi 2018 TRade FaciliT aTion Ta SkF oR ce SuR vey RepoRT 3 2018 TFT Survey Report Contents i. introduction . 1 ii. Survey d emographics .2 iii. c hallenges: Transparency and c ollaboration .5A. TransparencyB. Collaboration iv. Trade Facilitation performance: .8A. Operational Efficiency v. key Regulations and Reforms .9A. Single-window System B. Shanghai Free Trade Zone (FTZ)C. Nationwide Customs Clearance Integration RegimeD. Customs/CIQ Merger vi. expectations and Recommendations . 13 I. 摘要 . . 15 II. 受访企业情况 . . 16 III. 挑战：政策透明度与部门协作 . . 19A. 政策透明度B. 部门协作 IV. 贸易推进考虑因素 . . 21A. 运营效率 V. 改革与新政 . . 22A. 国际贸易单一窗口B. 上海自贸区C. 全国通关一体化改革D. “关检合并” VI. 展望与建议 . . 26I. Introduction The American Chamber of Commerce in Shanghais 2018 Trade environment Satisfaction Report is based on the 2018 Trade Environment Satisfaction Survey. The survey was conducted in early June and had responses from 70 companies. This report is an integral part of AmCham Shanghais Trade Facilitation Taskforce (TFT) dialogue with Shanghai Customs and Shanghai China Inspection and Quarantine Services (CIQ). AmCham Shanghai began a special initiative with Shanghai Customs in 2007, and began a parallel dialogue with Shanghai CIQ in 2012. Our annual Trade Environment Satisfaction Report provides concrete feedback and recommendations to improve the trade facilitation environment in Shanghai. According to this years survey results, Customs and CIQ have made further progress in lowering costs and reducing clearance times, but transparency and collaboration issues among trade facilitation authorities continue to pose challenges for American companies operating in Shanghai. Most respondents identified the single-window clearance system as the most helpful new reform. In contrast, not a single respondent labeled preferential policies from the Shanghai Free Trade Zone (FTZ) as such. Respondents ranked further fulfillment of the WTO Trade Facilitation Agreement 1(TFA) and more tangible benefits from qualifying as an Advanced Certified Enterprise / AA enterprise as the top two policies they were looking forward to in 2018. This survey was taken during a time of heightened regulatory uncertainty. Customs and CIQ were merged after the National Peoples Congress in March 2018. Survey respondents have high hopes that the merger will lead to less repetitive paperwork, simplified classification procedures and faster clearance times. However, only 38% of respondents reported they had received enough information about enterprise recertification, one of the first measures introduced after the merger. As the merger continues, there will likely be more changes in Customs procedures and regulations that will lead to more ambiguity in the next year. Trade tensions between the United States and China will add to the overall atmosphere of uncertainty, as both governments have introduced punitive tariffs that must be carried out by Customs authorities. Recommendations AmCham Shanghai is pleased that Shanghai Customs has made efforts to brief AmCham member companies on Customs policy developments and to seek out the views of the business community. To further facilitate trade, AmCham Shanghai urges that Shanghai Customs continues with additional measures to integrate Customs and CIQ operations beyond single-window declarations, and fully implement the trade facilitation reforms listed in the July 2018 Shanghai “100 Measures” initiative. In addition, more interactions and policy briefings will minimize regulatory uncertainties for companies. We also encourage the central government to play a positive role by introducing more reforms and preferential policies in the Shanghai FTZ and reexamining the possibility of establishing a Free Trade Port (FTP) with significant reforms in Shanghai. As for our member companies, we recommend they continue to engage with Customs authorities to gain a better understanding of Customs priorities and policies and upgrade their Customs Enterprise Rating to enjoy better trade facilitation measures. 1 In September 2015, China became the 16th WTO member to formally accept the WTOs Trade Facilitation Agreement (TFA). The Agreement includes provisions to “expedite the movement, release and clearance of goods, including goods in transit”. It also intends to enhance the cooperation between different customs and other related authorities on trade facilitation and customs compliance issues. 1AmChAm ShAnghAi II. Survey Demographics This years survey was conducted in early June 2018 and received 70 responses. The majority of participants came from the manufacturing sector (50%), followed by third-party logistics providers (21.5%) and the import/export sector (17.1%). A majority (64.3%) of respondents reported revenues exceeding US$100 million last year and 21.4% reported revenues between US$10 US$50 million. enterprise c lassification Ratings: increased a wareness This years results show a significant jump in company rating levels in both Customs and CIQs enterprise rating systems. Though the largest percentage of respondents remain in the Customs General What industry does your company operate in? 50% Manufacturing Third-party logistics provider Import/Export Trading Other Cross-border e-commerce 8.6% 2.8% 21.5% 17.1% Customs Enterprise Rating 2016 2017 2018 Advanced Certified Enterprise General Certified Enterprise General Credit Enterprise Discredited Enterprise Do not know 26 % 42 % 16 % 16 % 0 % 0 % 15 % 32.9 % 49 % 50 % 21 % 10 % 3 % 12 % 7.1 % 2018 TRade FaciliT aTion Ta SkF oR ce SuR vey RepoRT 2Certified Enterprise (50%) and CIQ Grade A level (40%) categories, there was a significant increase in those who have received Advanced Certified Enterprise and CIQ Grade AA level categorization. Companies in these two categories increased from 15% and 16% in 2017 to 32.9% and 39% in 2018, respectively. Last year a large number of respondents did not know their Customs and CIQ Enterprise ratings (12% and 30%, respectively). These rates dropped to 7.1% and 21% in this years survey. Understanding and upgrading Customs and CIQ enterprise ratings can help companies decrease risks and improve relationships with related government agencies. More importantly, companies with higher ratings are subject to fewer inspections and receive better services. In last years report we recommended to our member companies that they understand their ratings and it is encouraging to see that companies have followed that advice. a uthorized economic operators ( aeo ) In 2014, China adopted the World Customs Organizations (WCO) Authorized Economic Operator (AEO) classification system. AEOs, including Advanced Certified Enterprises and General Certified Enterprises, enjoy mutual recognition and preferential Customs treatment (for example, reduced port handling costs, insurance and logistic fees) from 33 countries/regions (as of December 2017), including 28 EU member states, Singapore, South Korea, Hong Kong SAR, and Switzerland. 2China is also actively pursuing AEO mutual recognition agreements with the United States, Japan, Malaysia and countries along its “Belt and Road Initiative (BRI).” 3 CIQ Enterprise Rating 2017 2018 Grade AA Grade A Grade B Grade C Do not know 16 % 31 % 21 % 2 % 30 % 0 % 0 % 21 % 39 % 40 % 2 Sometimes only Advanced Certified Enterprises (ACEs) are recognized in the Mutual Recognition. 3 The Belt and Road Initiative (BRI) is a development strategy first proposed by Chinese President Xi Jinping during his visit to Central Asia in 2013. It aims to promote economic cooperation and connectivity between China, Eurasian and Asia-Pacific countries by interlinking trade deals and infrastructure projects throughout the area. 3AmChAm ShAnghAi AEOs also enjoy priority inspection and release, a designated Customs coordinator (an assigned key Customs person of contact for request handling), and joint incentives from other government agencies. As China continues to expand its Customs relationship with other countries through the AEO platform, companies should consider applying for AEO certification and upgrading their Customs ratings. This will enable them to achieve higher clearance efficiency and other potential indirect benefits. n ew c lassification Measures In March 2018, Chinas General Administration of Customs of China (GACC) released the new Measures for Enterprise Customs Credit Rating (GACC Order No. 237), which took effect on May 1, 2018, and replaced the previous Interim Measures (Order No. 225). The new Measures include significant regulatory changes such as requiring companies to submit their enterprise credit information in an annual report and new treatment measures for companies in different categories. The new rules also attempt to bring Chinas system into closer alignment with the AEO regulations outlined in the WCO framework, which should lead to greater mutual recognition in the future. The new regulations clarified some provisions for preferential treatment for companies in different credibility rankings that had been included in the Interim Measures No. 225, including “higher,” “reduced” and “simplified.” The Measures state that “the average import/export inspection rate (hereafter referred to as “inspection rate”) for Advanced Certified Enterprise will be less than 20% than that of the General Enterprise Enterprises. The inspection rate for General Certified Enterprises will be 50% lower than that for the General Credit Enterprise. At the same time, Discredited Enterprises will be subject to an inspection rate of above 80%.” By providing preferential treatment (for example, potential exemptions of the guarantee deposit) to certified enterprises and punitive treatment (for example, longer waiting periods for recertification) to discredited enterprises, the Measures encourage companies to work toward higher rankings. In addition, the new regulation also introduces a joint supervision system that includes other government agencies such as the State Administration for Industry and Commerce, State Tax Bureau and the Ministry of Ecology and Environment. Do you feel that your company has accessed enough guidance from Customs on Customs enterprise recertification? 4.3% 17.1% 40.1% 38.5% Yes Neutral / Sometimes No, we cannot access enough information Not sure 2018 TRade FaciliT aTion Ta SkF oR ce SuR vey RepoRT 4Despite Customs efforts, 40% of respondents were ambivalent about whether they had enough information on this joint supervision system. Only 38% said they were able to obtain enough guidance from Customs on the enterprise recertification process, while 17% said they could not access enough information. Customs should continue to promote the measures and enhance the transparency and effectiveness of these new policies. III. Challenges: Transparency and Collaboration This is the first year our survey asked respondents to rank the challenges they faced. It shows that confusion over the person/department of contact for different Customs compliance matters and limited access to these departments are the top challenges for member companies. Other challenges included inconsistent or repetitive documentation requirements from Customs/CIQ in different locations, and failure to respect the minimum 30-day advance notice on regulation and content changes. We believe there will be improvement as Customs moves forward with its restructuring plan and introduces more integrated measures. a. Transparency A sizeable portion of respondents (47.1% and 42.9% respectively) indicated that both Shanghai Customs and Shanghai CIQ were more transparent, efficient and predictable compared to last year. On the other Please choose from the following challenges that may have most hindered your business. Confusion in department of contact in respect of