Since 18 December 2025 Hainan has operated as a special customs supervision area: the first line, between Hainan and overseas, is open, and the second line, between Hainan and the rest of China, is controlled. Zero-tariff treatment moved from a positive list of goods to a list of goods that stay taxable, so most imports now qualify — which moves the question from whether the goods are covered to whether the importing entity is, and whether it can show where the goods went.
The obligations follow the goods. An eligible entity keeps an electronic account book, limits who the goods can pass to on the island, and owes tax when goods or products cross the second line — unless a processing route applies, where Hainan adds at least 30% of value. Zero-tariff equipment and vehicles stay under supervision after clearance, so a transfer or a change of use can carry a price long after the import.
Declarations are filed by a registered customs declaration enterprise, which we instruct and whose work we check; HainanInc is not a customs declaration enterprise and does not file them itself. Bonded maintenance, authorised-economic-operator status, and freight are referred to specialists rather than offered here.
Services in this practice area
Zero-Tariff Eligibility and Account Setup
Eligibility assessment, application support, and record design for the Free Trade Port's zero-tariff treatment of imported goods after island-wide closure.
- Coverage has flipped
- Eligibility belongs to the entity
- An account book that reconciles
- Filed by a declaration enterprise
Processing Value-Added Duty Exemption
Feasibility modelling, filing support, and annual review for the route by which goods processed in Hainan can enter the mainland free of import duty.
- A calculation, not an impression
- Duty, not every tax
- Modelled before the site is fixed
- Reviewed every year
Zero-Tariff Equipment, Vehicles and Yachts
Supervision of zero-tariff production equipment, vehicles, and yachts after clearance, including transfers, changes of use, and disposals.
- Admitted for a declared use
- Transfers priced before they are agreed
- Mechanism, not a quoted figure
- Exit planned with the assets in view
Second-Line Movement and Mainland Sales
Mapping and costing the flows of goods and products from Hainan into the mainland across the second line, and the declarations that go with them.
- A deferral, not a forgiveness
- Three flows, three costs
- A shorter form, the same amount
- Prices that include the second line
The saving is taken at the border; the proof is asked for later
The duty saved on entry is the visible number. The exposure sits afterwards: an account book that does not reconcile, a transfer to a party that is not an eligible entity, or a product sold into the mainland without the value-added calculation behind it. Each is cheap to prevent when the record is built at the start and expensive to reconstruct when customs asks.
We design the record with the entity's operations team and the declaration enterprise before the first import, and check it at each stage. Where the saving does not hold up for a given business — because the goods stay taxable, or the entity is not eligible — we say so before an import is planned around it.
Why choose HainanInc?
One accountable team
A single point of contact carries your engagement from first filing through to ongoing compliance — not a rotating cast of specialists.
Documented calendars
Every recurring obligation is tracked to a date, not a quarter, so nothing lapses unnoticed.
Built for administrative reality
Filing sequences and document chains are built around how Hainan's processes actually run, not the published version of them.
Published fees, fixed scope
Starting fees are published, diagnostics are fixed-price, and the final fee is agreed in writing before work starts — not after an invoice arrives.
Direct access to the people doing the work
Questions go to the team handling your filing, not to an account manager relaying them onward.
Substance-first structuring
Advice accounts for what regulators actually look for when reviewing qualification, not only what qualifies on paper.
Related insights
View all insightsProcessing Value-Added After Island-Wide Closure: What Changed and What Still Has to Be Proved
The route that lets goods processed in Hainan enter the mainland free of import duty became useful to more businesses at closure. It did not become easier to claim without evidence.
Park Selection in Hainan Decides More Than Rent
Hainan's incentives are not uniform across the island. Several are scoped to particular parks, which makes site selection a policy decision taken early — and an expensive one to revisit.
Every Major Hainan FTP Tax Relief Now Expires on the Same Day
The corporate income tax reduction, the talent income tax cap and the capital expenditure relief were each extended separately in 2025 — and each now runs to 31 December 2027. That common end date is a planning fact, not a footnote.
Our other practice areas
A single engagement rarely stays confined to one practice area. Explore the rest of what we cover in the Hainan Free Trade Port.
Our services
Our practice areas cover the whole life of a presence in Hainan — from the market-entry assessment made before anything is filed, through formation, tax incentives, customs and zero-tariff compliance, and annual compliance, to the work permits, outbound investment, and deregistration around it. One engagement model means a single accountable team across all of them.
