A cargo ship laden with goods is preparing to dock at the Port of Los Angeles. Among its contents are 10 pallets of large packages and 250 paper bags of smaller items. As the vessel approaches, a critical question emerges: Should U.S. Customs declarations list the count of large outer packages or the individual smaller units? This decision carries significant implications for both customs clearance efficiency and trade compliance.
Chinese Export Declaration Standards
Under China's Customs Declaration Form Completion Guidelines , the "package count" field must reflect the actual number of externally packaged units. In this scenario, the declaration would list "10" as the package count, with "pallets" specified as the packaging type. While some exporters declare inner package quantities, strict adherence to reporting outer packaging remains the officially endorsed approach.
U.S. Import Declaration Requirements
U.S. Customs and Border Protection employs a more nuanced approach centered on the "visible inner package" principle. When inner packages remain clearly discernible through outer packaging (such as transparent wrapping), importers must declare the individual unit count. Conversely, when outer packaging completely obscures contents (like solid crates or wrapped pallets), declarations may use the larger container count.
In our Los Angeles-bound shipment example, the paper-covered pallets conceal their contents, permitting declaration of just 10 packages. The bill of lading would accordingly show "10 PKGS" (packages) rather than specifying pallets.
Alternative Declaration Methods
For mixed packaging scenarios, U.S. Customs allows secondary declaration through the goods description field. Shippers might specify: "10 Pallets containing 250 Paper Bags." This method proves particularly useful when inner packages become visible only during customs inspection.
Manifest Accuracy Considerations
The cargo manifest submitted to U.S. Customs must precisely match other shipping documents. Discrepancies between manifest declarations and actual packaging can trigger customs inspections, potentially causing delays and incurring storage fees at port facilities.
Practical Recommendations
Exporters should carefully evaluate packaging visibility when completing U.S. customs documentation. For transparent or open packaging (like shrink-wrapped pallets showing individual bags), the inner package count becomes mandatory. Proper documentation practices include:
• Verifying packaging visibility before completing declarations
• Maintaining uniform package counts across all documents
• Clearly specifying packaging types in all relevant fields
• Consulting customs brokers for complex packaging scenarios
In our initial case, the paper-covered pallets justify declaring 10 packages. However, had the shipment used transparent wrapping revealing 250 paper bags, customs declarations would require reporting the higher count with "Paper Bags" as the specified packaging type.
Understanding these nuanced requirements helps exporters minimize customs delays and ensure smooth transatlantic trade operations. Proper package count declaration serves as both a regulatory requirement and a strategic advantage in international shipping.