Cross-border e-commerce or general trade? The two main routes into China for a Canadian brand

Short answer: A Canadian brand can sell into China through cross-border e-commerce (CBEC) or general trade. With CBEC, shoppers in China buy your product for personal use on a platform such as Tmall Global or JD Worldwide, and products on China's CBEC import list skip first-import registration and filing. Within limits of RMB 5,000 per order and RMB 26,000 per shopper a year, CBEC orders pay a 0% tariff and 70% of the normal import VAT and consumption tax. With general trade, a Chinese importer pays full duty and tax and the product must meet Chinese standards, labelling and registration rules, but it can then be resold to stores, restaurants and distributors, which CBEC goods may not be.

The two routes side by side

Route 1: cross-border e-commerce

How goods come in. Notice No. 486 covers two models. In the bonded model (customs code 1210), you ship stock ahead to a warehouse in a special customs zone or bonded logistics centre, and each order clears customs when a shopper buys. In the direct-mail model (code 9610), each order ships from abroad through a postal or express operator, under GACC Announcement No. 194 of 2018.

Who is responsible. The overseas seller owns the goods, is primarily responsible for their quality and safety, and must appoint a company registered in China that registers with customs, declares truthfully and bears joint civil liability. The consumer is the taxpayer; the platform, logistics company or customs broker withholds the tax (Notice No. 486; Tariff Law, Art. 3).

Which products. Only goods on the CBEC import list, often called the positive list, qualify. The list was adjusted from March 1, 2022, and an August 2025 report from USDA's Shanghai office describes that as the latest update, with 1,476 items.

How it's taxed. CBEC isn't tax-free. Since 2019, the limits have been RMB 5,000 per transaction and RMB 26,000 per person per year. Tax is charged on the actual price, including shipping and insurance. Within the limits, the tariff is provisionally 0% and import VAT and consumption tax are charged at 70% of the normal amount, under a 2016 tax notice. For a product at China's standard 13% VAT rate (VAT Law, Art. 10) with no consumption tax, that works out to an effective rate of 9.1%. A single-item order over RMB 5,000 can still come in through CBEC if it stays within the annual limit, but it pays full tariff and taxes; once a shopper goes over the annual limit, imports are treated as general trade.

What CBEC skips, and what it doesn't. CBEC goods are supervised as personal-use items, so first-import licences, registration and filing don't apply, except for disease-related import bans and major safety risks. Shoppers must first accept a risk notice that the product follows home-country standards, may lack a Chinese label (a Chinese e-label is shown online) and is for personal use only. Customs still monitors safety risks and carries out any necessary quarantine before sale (Notice No. 486). For cosmetics, the Trade Commissioner Service says CBEC carries no registration or filing requirement. For food, CFIA says CBEC imports may not be subject to all of China's facility registration requirements and tells exporters to confirm them with their Chinese importer.

Route 2: general trade

Your Chinese importer, as consignee, is the taxpayer (Tariff Law, Art. 3). It pays the applied tariff, any consumption tax, and import VAT calculated on the customs value plus duty and consumption tax (VAT Law, Art. 14).

For food, China's Food Safety Law requires that:

• imported food meets China's national food safety standards and passes inspection (Art. 92);
• the overseas exporter or its agent and the Chinese importer file with China's customs authority, and the overseas producer is registered (Art. 96), as our GACC registration guide explains;
• prepackaged food carries a Chinese label showing the country of origin and the agent in China, or it can't be imported (Art. 97);
• a health food imported for the first time is registered with China's market regulator, or filed if it supplements vitamins or minerals (Art. 76).

For cosmetics sold outside CBEC, the Trade Commissioner Service says "special" cosmetics, such as hair dye, whitening products and sunscreen, need registration with the National Medical Products Administration (NMPA), and ordinary cosmetics need filing with a provincial authority. Registration and filing can also call for animal-test data, and NMPA Announcement No. 70 widened the animal-test exemptions in July 2026.

Which products fit which route

Platforms and partners on each route

For CBEC, Export Development Canada names Alibaba's Tmall Global and JD.com's JD Worldwide among the top platforms for agri-food, both of which let foreign producers sell to Chinese consumers without a physical presence in China. Global Affairs Canada told The Canadian Press that the Trade Commissioner Service has worked closely with JD Worldwide. For general trade, your partner is a Chinese importer or distributor.

Starting with one route and adding the other

The Trade Commissioner Service calls CBEC a time- and cost-saving way for Canadian cosmetic brands to enter China, and says registration and filing are required for companies seeking large sales volumes through general trade. USDA's Shanghai office advises launching on CBEC with a few high-potential products to test your approach. Its Beijing office notes that because most popular brands already sell through traditional trade, CBEC platforms are interested in smaller exporters with products new to China.

A practical sequence: test on CBEC, register or file what sells, appoint an importer for stores and food service, and keep CBEC for the rest of your range. Keep the channels separate: CBEC goods may not be resold, bonded CBEC goods in principle can't be offered for pickup outside special customs zones, and market regulators act against CBEC-sourced goods sold in China's domestic market (Notice No. 486).

What this means for your business

1. Check the CBEC list first. Confirm your Chinese tariff line with your platform or importer. If it isn't listed, plan for general trade.
2. Check the extra tariffs. China's 2025 announcement of extra tariffs on some Canadian goods keeps existing bonded and tax-relief policies in place but doesn't reduce or waive those tariffs, so ask your platform how they apply to CBEC orders. Some of them are paused until December 31, 2026 (see our tariff guide), and they follow a product's origin, not its shipping route (Tariff Law, Arts. 11 and 19).
3. Start registrations early for products you plan to move into general trade.
4. Confirm the details with the Trade Commissioner Service, your importer or your customs broker.

How QX can help

Customs declarations, product registration and store setup run through your importer or CBEC agent, China's regulators and each platform's onboarding team. QX takes care of the market side on either route: we work with you on China market positioning and choosing the right channel, prepare your Chinese-language brand and product materials, and run your Xiaohongshu, WeChat and Douyin accounts, so shoppers and buyers who look you up can understand your product, find it and get in touch. Start with a free 20-minute consultation and leave with a clear view of which route to try first and a practical next step.