沥青HS编码与中国进口手续 · Bitumen HS Code 2713.20 and Import Clearance in China

石油沥青的国际税则六位子目为2713.20，但报关单上填报的是更长的本国商品编号，须由持牌报关企业按现行税则核定，本页不给出编号。进口环节增值税为13%，关税税率须按具体子目和原产地在现行税则中查实。2018年机构改革后，原出入境检验检疫（CIQ）职能已并入海关总署，仍把CIQ描述为独立机构的说法已经过时。桶装固体沥青一般不按危险货物运输，装运温度达到或超过100 °C时为UN 3257第9类。合同、信用证与报关单的品名必须完全一致。

Petroleum bitumen is classified under HS subheading 2713.20 (石油沥青), which is the six-digit international part of the code and is common to every customs territory that applies the Harmonized System. It is not the code that clears a container. Below six digits each territory extends the number, and the commodity code entered on the Chinese customs declaration (报关单) is that longer national code together with the regulatory condition codes attached to the tariff line — which is why the full national subheading has to be confirmed in writing with a licensed customs broker (报关企业) against the current tariff schedule before the cargo is booked, and why this page gives no code beyond the six digits. Import value added tax on goods is 13 %, assessed on the duty-paid value plus duty plus any consumption tax the classification attracts. No duty rate is stated here: the applicable rate depends on the specific subheading and on the origin evidenced by the certificate of origin, and it must be read from the current tariff schedule. The 2018 institutional reform merged the former entry-exit inspection and quarantine (CIQ) function into the General Administration of Customs (中国海关总署, GACC) and merged the two declaration forms into one, so any page or agent still describing CIQ as a separate agency issuing its own certificate is working from an out-of-date picture. On dangerous goods, state the condition rather than a blanket claim: solid bitumen packed in drums or bags and shipped at ambient temperature is generally not handled as a dangerous good, while bitumen carried at or above 100 °C is UN 3257, Class 9. And the goods description on the sales contract, the letter of credit and the customs declaration must be one description, because a bank refusing documents and a customs officer questioning a declared description are two independent ways for the same wording problem to stop a shipment.

六位是国际统一部分 · What the six digits are

The Harmonized System is maintained by the World Customs Organization and its first six digits are common to every customs territory that applies it. Chapter 27 covers mineral fuels, mineral oils and products of their distillation, bituminous substances and mineral waxes. Within it, heading 27.13 covers petroleum coke, petroleum bitumen and other residues of petroleum oils or of oils obtained from bituminous minerals, and the subheading 2713.20 is petroleum bitumen (石油沥青).

A straight paving bitumen — penetration grade, viscosity grade or performance grade — normally sits in 2713.20. So does the same material in a drum, in a jumbo bag, in a tank container or in a ship’s tank, because packing does not change the classification. What changes the classification is what the material is: a residue of petroleum refining, not a mixture built from one, and not a naturally occurring bitumen.

本国商品编号才是报关用的编码 · The national code is longer, and it is the operative one

Below the six digits every customs territory extends the code for its own tariff and statistical purposes. China is no exception, and the number a declarant enters into the single window system is the full national commodity code, not the six-digit subheading. Attached to that tariff line are the codes that actually govern the shipment: the regulatory condition codes (监管条件) that indicate whether a licence, a permit or a documentary condition applies, and the inspection and quarantine category codes that indicate whether the line is subject to statutory inspection (法定检验).

This is the practical reason the six digits are not an answer. Two cargoes can both be correctly described as petroleum bitumen and be presented on tariff lines whose attached conditions differ, and it is the attached conditions — not the commodity name — that determine whether an additional document is required before release. Confirm the full national commodity code in writing with a licensed customs broker (报关企业), against the current edition of the tariff schedule, before the cargo is booked. This page deliberately stops at six digits because a national code quoted from memory or copied from a competitor’s page is exactly the kind of detail that is silently revised between tariff editions.

Where the volume justifies it, GACC also operates an advance ruling procedure (预裁定) through which a registered consignee can apply for a binding decision on classification, origin or valuation ahead of import. It has to be applied for well before the intended shipment and the decision is issued to that applicant for that commodity, so it is a tool for a recurring trade rather than for a single container. For a first shipment, a broker’s written classification opinion supported by the certificate of analysis and the technical data sheet is the normal substitute.

边界在哪里 · Where the boundaries of 2713.20 run

Three boundaries matter in this trade, and none of them follows the ordinary commercial use of the word bitumen.

• Against heading 27.14 — natural bitumen. Heading 27.14 covers bitumen and asphalt that occur naturally, together with bituminous or oil shale, tar sands, asphaltites and asphaltic rocks. Gilsonite and other natural asphaltites belong to that conversation, not to 2713.20. A cargo of natural material described loosely as asphalt is in a different heading entirely.
• Against heading 27.15 — bituminous mixtures. Heading 27.15 covers bituminous mixtures based on natural asphalt, on natural bitumen, on petroleum bitumen, on mineral tar or on mineral tar pitch, and its own heading text names bituminous mastics and cut-backs as examples. This is the boundary that catches exporters out. A cutback bitumen is not classified in 2713.20 merely because its base binder was. The blend, not the base, is what is being imported.
• Against subheading 2713.90 — other residues. The rest of heading 27.13 covers petroleum coke and other residues of petroleum oils. A residue that is not petroleum bitumen does not become petroleum bitumen because a contract calls it that.

Modified binders and emulsions do not resolve automatically. A polymer modified bitumen and a bitumen emulsion each raise a genuine question about whether what is being presented is petroleum bitumen or a preparation based on it, and the answer depends on the composition and on how the classification rules are applied to it. That is a question for the broker with the specification in front of them, and it should be settled before the cargo is booked rather than argued at the port.

为什么边界上有钱 · Why the boundary carries money

Classification is not a filing formality. Different tariff lines can carry different duty treatment, different attached regulatory conditions and, where a line falls within a category of refined oil products subject to consumption tax (消费税), a different tax base as well. Whether consumption tax reaches a particular cargo is a question of the classification and of the current tax rules, and it is not one to guess at — it is one to put to the broker in writing.

It is also why customs reads the declared description against the certificate of analysis rather than accepting it on its own. The description on the declaration is a statement about what is inside the container; the COA, the technical data sheet and the safety data sheet are the evidence offered for that statement. Where the boundary between a petroleum bitumen and another petroleum residue carries a different fiscal consequence, an authority will read those documents together, and a declaration supported by a batch COA showing measured penetration, softening point, flash point and solubility is a materially stronger position than one supported by a description alone.

不要让口语词决定编码 · Do not let loose vocabulary pick the code

English is unhelpful here. In North American usage asphalt means the binder; in British and most export usage it means the mix, and bitumen means the binder. Chinese 沥青 covers both petroleum and natural material, which is why the precise term for the 2713.20 product is 石油沥青. Write the precise term in the contract, in the invoice, on the packing list and in the declaration, and write it identically in all four. A document set that drifts between asphalt, bitumen, 沥青 and 石油沥青 invites a reader to wonder which heading is really in play, and the person doing the wondering may be the one holding the container.

2018年关检融合 · The reform that makes older guidance wrong

Until 2018, an import into China dealt with two agencies. The customs authority handled classification, valuation, duty and release. A separate entry-exit inspection and quarantine service — universally referred to in trade correspondence as CIQ — handled inspection, quarantine and the certificates attached to it, and it took its own declaration on its own form.

The 2018 institutional reform ended that split. The entry-exit inspection and quarantine function was transferred into the General Administration of Customs (中国海关总署, GACC), and during the same year the customs declaration form and the inspection declaration form were merged into a single declaration. The trade shorthand for the change is 关检融合 — customs and inspection integration — and the practical result is one authority, one declaration and one set of codes on the tariff line.

The reason this matters commercially is not administrative tidiness. It is that a great deal of the bitumen import guidance in circulation, including material published by agents who quote it confidently, still describes CIQ as a separate agency issuing its own certificate and taking its own filing. That picture is out of date. An agent who offers to obtain a separate CIQ certificate, or who builds a timeline around a second agency’s clearance step, is describing a process that no longer exists in that form, and the discrepancy is a useful early signal about how current the rest of their advice is.

检验检疫职能并没有消失 · The inspection function did not disappear

It is equally wrong to draw the opposite conclusion. The function was moved, not abolished. Statutory inspection requirements, sampling, documentary checks and quarantine controls all still exist; they are now administered by customs, and whether they apply to a particular cargo is signalled by the regulatory condition and inspection category codes attached to the national tariff line. That is one more reason the full national commodity code has to come from the broker rather than from the six-digit subheading: the six digits carry no attached conditions at all.

关税 · Duty, and why no rate appears on this page

China’s tariff schedule sets out several rate columns — most favoured nation, agreement rates under the trade agreements China is party to, and general rates — and which column applies to a given consignment depends on the subheading and on the origin of the goods. Origin is not a matter of where the vessel sailed from; it is a matter of what the certificate of origin evidences and whether it is the form required to claim a preferential rate.

No duty rate is stated on this page, deliberately. Rates are revised, provisional rates are applied and withdrawn, and agreement schedules phase over time. A rate quoted on a supplier’s web page and relied on in a landed-cost calculation is a liability, not a service. The correct procedure is to confirm the rate against the current tariff schedule for the specific national subheading and the specific origin, with the broker, at the time of the transaction — and to make sure the origin documentation on order is the documentation that supports the column being relied on.

完税价格 · The duty-paid value

Duty and import VAT are not assessed on the invoice figure alone. The duty-paid value (完税价格) for imported goods is built from the transaction value, adjusted to include transport, associated charges and insurance up to the place of entry into China. In Incoterms language it therefore behaves like a CIF-type basis, which has a consequence buyers regularly miss: moving from CFR to CIF, or negotiating freight, changes the tax base, not just the freight line. Two offers at the same FOB price with different freight and insurance arrangements do not produce the same landed cost, and the difference is amplified by the duty and VAT assessed on top.

进口环节增值税 13 % · Import VAT

Value added tax on goods is levied at import at 13 %. The base is not the duty-paid value alone: it is the duty-paid value plus the duty payable plus any consumption tax that the classification attracts. Whether consumption tax reaches a particular cargo depends on the classification and on the current tax rules, and this page states no position on it — it is a question for the broker and the importer’s tax adviser, put in writing against the confirmed national subheading.

The compounding matters when the numbers get large. Because VAT is charged on a base that already includes duty, an error in classification that moves the duty treatment moves the VAT as well, and a container that was mis-declared cheaply becomes an expensive correction. This is another argument for settling the code before the cargo sails rather than after it arrives.

缴款书与进项抵扣 · The payment certificate, and why the name on it matters

For a Chinese buyer that is a general VAT taxpayer, import VAT is normally a cash-flow item rather than a cost: it is creditable as input VAT against output VAT. The instrument that makes the credit possible is the customs import VAT payment certificate (海关进口增值税专用缴款书), issued after payment.

Two practical points follow, and both are about names rather than numbers. The certificate is issued in the name of the entity shown as consignee on the declaration, and it is that entity that can claim the credit. If the cargo is declared through an agent under an arrangement in which the consignee of record is not the company that will consume or resell the material, the credit can end up detached from the party carrying the cost. And the consignee on the bill of lading, the applicant on the letter of credit and the consignee on the declaration need to be reconciled deliberately at contract stage, not discovered to be different when the documents are presented. For a foreign seller this is not merely the buyer’s problem: a buyer who loses a 13 % input credit on a technicality will look for somewhere to recover it, and the negotiation will land on the contract.

申报期限与放行后监管 · Deadlines, and what happens after release

Chinese customs procedure runs on statutory clocks. Under the Customs Law (《中华人民共和国海关法》) the consignee is required to declare imported goods within fourteen days from the day the means of transport declares its arrival, and a late declaration fee accrues daily thereafter on the value of the goods. Duty assessed by customs is payable within fifteen days from the issue of the duty memorandum, with a late payment surcharge after that. Clearance is also not the end of the file: under the customs audit rules, customs may carry out post-clearance audit within three years of release, which is why the full document set and the retained samples should be archived rather than filed and forgotten. Deadlines and procedural rules are periodically amended — confirm the current position with the broker rather than relying on a figure read on a web page, this one included.

三个读者，三套规则 · Three readers, three rule sets

The goods description travels through three checkpoints:

• The sales contract. Read by the parties, and by an arbitrator if it ever gets that far. It defines what was actually sold — the grade, the governing standard, the quality class where one applies, the packing and the inspection arrangement.
• The letter of credit. Read by the issuing and nominated banks against UCP 600. The commercial invoice must show a description of the goods corresponding with the description in the credit; other documents may describe the goods in general terms provided they do not conflict with the credit; and data in any document must not conflict with data in another document or with the credit. Banks deal in documents, not goods, and a conflict on the face of the papers is a discrepancy whether or not the cargo is perfect.
• The customs declaration. Read by GACC against the tariff schedule and the supporting documents. Here the description is a legal statement about what is in the container, tied to a commodity code and evidenced by the invoice, the packing list and the certificate of analysis.

The three readers do not talk to each other, and each has its own remedy. That is precisely why one inconsistency can produce three separate problems from a single drafting decision made months earlier.

沥青贸易里最常见的六个不一致 · The six mismatches that recur in this trade

• The grade is named in two systems that do not mean the same thing. A contract says Bitumen 60/70 while the buyer’s project specification and the credit say 70号道路石油沥青. These are not equivalent statements. Under JTG F40-2004 the number with a hash is the nominal penetration and the acceptance band sits either side of it, so 70# covers penetration 60–80 (0.1mm), whereas in ASTM 60/70 the two numbers are the band. A 60/70 cargo normally sits inside the 70# band on penetration, but the two names are making different claims, and a bank comparing a certificate that says 60/70 against a credit that says 70# is entitled to call it a discrepancy. The fix is to name both, with the standard behind each: Bitumen 60/70 to ASTM D946, offered against 70号道路石油沥青 to JTG F40-2004, class as specified.
• The quality class appears in the credit and nowhere else. A credit calling for A级 material is calling for a class that is set by wax content (蜡含量), ductility at 10 °C, penetration index (针入度指数) and the residue requirements after ageing — not by penetration, which is identical across classes. A certificate of analysis that reports penetration and softening point and is silent on the class-linked lines does not evidence the class, and the bank is not required to infer it.
• Net weight against gross weight. Steel drums are heavy and their tare is real. Where the packing list, the invoice and the declaration do not agree on whether the quantity is net of drum tare, the quantity figure disagrees with itself across the file. The published loading figures are fixed by the container and are the right sanity check: 150 kg drums load 80 drums and 12 MT per 20 foot FCL, 180 kg drums load 80 drums and 14.4 MT, 185 kg drums load 80 drums and 14.8 MT; jumbo or poly bags of 1 MT load 20 bags and 20 MT; a bitutainer carries 20–25 MT. Confirm in the contract that drum tare is excluded from the invoiced net weight and then declare the same figure everywhere.
• The packing description is vague in one document and specific in another. A credit calling for new steel drums and an invoice saying drums is a conflict on its face, and it is also a real commercial question, because reconditioned drums are the most common source of contamination disputes.
• Origin drifts. The certificate of origin, the invoice and the declaration must name the same origin, and the certificate must be the form that supports the tariff column being claimed. Origin is not the port of loading and it is not the flag of the vessel.
• The words asphalt, bitumen, 沥青 and 石油沥青 are used interchangeably. They are not interchangeable, and the drift between them can point a reader toward a different heading — 27.14 for natural material, 27.15 for mixtures and cutbacks. Fix one bilingual description and never paraphrase it.

后果链 · The consequence chain

Follow a single inconsistency through and it costs money in four places.

At the bank. Documents presented with a discrepancy can be refused. In practice the seller then either corrects and re-presents, if time under the credit allows, or asks the buyer to waive the discrepancy. The moment a waiver is needed, commercial leverage moves to the buyer — on a falling market that is not a theoretical concern, because a buyer who has lost interest in the cargo now has a documentary reason to say so. Discrepancy handling charges are deducted regardless of the outcome.

At customs. A declaration whose description does not match the goods or the supporting documents can be queried, and the shipment stops while it is resolved. Amending or cancelling a filed declaration is a formal procedure requiring customs approval — it is not a correction the declarant can simply make. Where an inaccurate declaration affects duty collection, trade control administration or the order of customs supervision, the administrative penalty rules provide for warnings and fines. And the enquiry itself, however it ends, consumes the clock against the statutory declaration deadline.

At the port. While the paperwork is being argued, the container is somewhere. Demurrage on the container and storage at the terminal accrue daily and are indifferent to whose fault it was. For drummed cargo sitting through a wet season, prolonged uncovered storage is also a cargo-condition risk, not only a cost.

In the buyer’s tax position. If resolving the problem changes the declared value or the party of record, the import VAT payment certificate may not end up in the name of the entity that expected to claim the input credit. A 13 % credit lost on a technicality is a serious number on a container of bitumen, and the buyer will come back to the contract to look for it.

做法 · The practice that prevents all of it

Write one bilingual goods description before the credit is opened. Make it carry the grade in whichever systems apply, the governing standard and its edition, the quality class where the Chinese specification uses one, the packing with the drum type and net weight, and the inspection arrangement. Then paste that identical string into the contract, the credit application, the invoice, the packing list, the certificate of analysis and the declaration instruction to the broker. Do not improve the wording in any one of them. A description that is slightly clumsy in six identical copies clears; a description that is elegant in six different versions does not.