Our company has observed the October announcement from the General Administration of Customs regarding the voluntary disclosure of violations. Could you please highlight any major changes in the latest requirements?


The voluntary disclosure system, based on the laws and regulations such as the Regulations of the People's Republic of China for Customs Audits and its implementing measures, represents a fault-tolerant management model implemented by Customs to promote law-abiding practices among import and export enterprises. The proven system reduces Customs costs, enhances law enforcement efficiency, and encourages businesses to adopt standardized management. The current implementation measures aim to unlock policy dividends in three key areas.

The first improvement expands the scenarios for voluntary disclosure exempt from administrative penalties. It broadens the scope from tax-related violations to breaches of Customs regulations. This explicitly includes issues affecting national export tax refund management and introduces various new scenarios. For instance, situations where processing trade enterprises, due to process improvements or other reasons, report actual consumption lower than declared, actions affecting Customs statistical accuracy, actions disrupting Customs regulatory order, and violations falling under Article 18 of the Regulations of the People's Republic of China on the Implementation of Customs Administrative Punishment. It also covers six types of violations of Customs inspection and quarantine regulations.

The second improvement involves further extending the time limit for voluntary disclosure without incurring administrative penalties. The previous maximum period was within one year, and it has now been extended to within two years. This adjusted timeframe better aligns with practical aspects of enterprise compliance self-audits, providing businesses with a more ample window for proactive self-examination and effectively maximizing the benefits of the system.

The third improvement is a more precise description of "the same" violation of Customs regulations. It now states that voluntarily disclosing the same violation of Customs regulations for the second time or more within one year (12 consecutive months) will not be subject to the provisions of this announcement. Additionally, it clarifies that "the same violation of Customs regulations" refers to actions of identical nature and violating the same legal article and clause. This refinement facilitates optimal use of the voluntary disclosure system by enterprises.