China 1039 Exports: From Market Purchases to a Shipment Ready to Load

Several suppliers. Different packing lists. Cartons arriving on different days. For an Indonesian buyer sourcing small orders in China, bringing everything together takes more than a freight booking. The purchase records, cargo received and export declaration need to tell the same story.

China’s market procurement trade mode—customs supervision code 1039—provides an export route for qualifying purchases from recognized market clusters. ECBEC helps buyers connect the eligibility review with cargo collection, carton checks and loading preparation, so problems can be identified while there is still time to resolve them. [1][2]

Market sourcing: a shop at Yiwu International Trade Mart.

Start with the purchase, not the container

1039 applies to goods purchased in a recognized market cluster and exported by a qualified market procurement operator. The goods must pass the required commodity recognition process, and the relevant transaction data must be recorded through the market’s management system. The operator must complete the applicable local registration and Customs recordal. [1]

The value of goods on a single customs declaration must not exceed US$150,000. This is a declaration limit, not a limit per supplier or per container. Supplier count alone does not determine eligibility, and transporting factory goods through a pilot city does not establish a qualifying market purchase. [1][2]

Bring the order list to ECBEC early

Send us the supplier list, purchase locations, product details, values, packing information and cargo-ready dates. We can help coordinate the eligibility review, collection schedule, cargo reconciliation and loading plan, then connect them with the export handoff and sailing options. Where the proposed purchases do not fit 1039, an appropriate export arrangement needs to be assessed before the cargo is committed to that route.

Turn separate supplier lists into one cargo picture

Consider an illustrative order: the buyer purchases ceramic mugs from one market vendor and household storage items from another. One packing list uses product names; the other uses internal item codes. The warehouse receives fewer cartons than expected, and a vendor changes the quantities before delivery. Until those differences are reconciled, the buyer cannot rely on the original order list as a loading or declaration record.

Warehouse handling and inventory work: each received package needs a traceable record.

ECBEC can coordinate supplier deliveries and build a consolidated cargo list showing the supplier, product description, quantity, value, carton marks, package count, weight and dimensions. When a shortage, damaged package or inconsistent description appears, we can help the buyer and supplier resolve it before the cargo is handed over for export. Product details such as material and use should be collected where needed for classification and regulatory review.

For a proposed 1039 shipment, we coordinate with a qualified market procurement operator and customs broker to check the purchase location, commodity eligibility and system records. The warehouse list supports that work; the formal transaction and declaration requirements still have to be met. [1][3]

Simplified declaration still needs complete records

When the transaction list linked to one declaration contains more than five commodity varieties, eligible goods may use simplified declaration. The five highest-value varieties are declared separately. The remaining eligible goods are grouped by tariff chapter, using the code of the highest-value commodity in each chapter and aggregating the relevant quantities and values. [1]

Goods subject to export duty, inspection or quarantine, and other Customs exclusions cannot use this simplified treatment. Prohibited or restricted export goods, unrecognized goods and other excluded goods cannot use 1039. These are separate checks: a product’s inspection requirements and its eligibility for simplified declaration must both be reviewed. [1][2]

Plan the loading around the verified cargo

Once the received cargo and records have been reconciled, ECBEC can coordinate packing adjustments, loading arrangements and the export handoff. Carton dimensions and weights help determine space and handling needs; package condition and the characteristics of the goods inform stacking, separation and securing. Photos taken during loading can document the cargo placement and visible package condition.

Loading in practice: forklift transfer and pallet movement inside a container, photographed in Thailand.

Keep tax, payment and destination checks aligned

Qualifying market procurement exports by market vendors, either directly or through an entrusted operator, are covered by the specific VAT exemption policy. Exemption is different from an export rebate. The prescribed transaction recording, entrustment documents and tax procedures must be followed. The seven-department policy letter issued in 2022 (Shang Mao Han [2022] No. 479) states that transactions settled in cash are not eligible for market procurement trade; foreign exchange receipts require a genuine trade background and the applicable bank checks. [2][3][4]

1039 governs the China export arrangement. Indonesian import requirements must be checked separately for the actual products, including classification, importer status and any required permits or standards. The buyer, qualified operator, bank and relevant customs and tax professionals should confirm their respective requirements before shipment.

Policy sources

[1] Customs Announcement No. 221 of 2019

[2] Seven departments pilot policy of 2022

[3] STA market procurement VAT exemption rules

[4] SAFE market procurement receipts guidance