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NVOs Can Cancel Supplemental Bonds for Services in China Under New Registration Process, NCBFAA Says

Non-vessel operating common carriers (NVOCCs) performing services in China no longer require a cash deposit at a Chinese bank or a supplemental bond on file with the Federal Maritime Commission to register with Chinese authorities, provided that they are licensed or registered with the FMC, according to an update emailed Aug. 19 by the National Customs Brokers & Forwarders Association of America. But they don’t have to cancel existing bonds either, the NCBFAA clarified.

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It appears that the new [Ministry of Transportation] registration process no longer requires any cash deposit or Supplemental Bond for FMC licensed or registered NVOCCs,” the NCBFAA said. The FMC supplemental bond process still exists, so while there “is no requirement that these bonds be canceled,” companies providing NVOCC services into or out of China “can now take the steps necessary to cancel those PRC Supplemental Bonds,” the trade group said.

Also, contrary to an update the NCBFAA sent out in July on the subject, China will not require the Social Security number of a contact person performing NVOCC services, the trade group said. “the company's EIN would generally suffice to fill in that data element in the registration template,” it said.

As detailed by the NCBFAA in July, the Chinese Ministry of Transportation recently reformed its NVOCC registration process so that there is “no longer a requirement to provide significant documentation in order to obtain or renew a company's registration with MOT; instead, the various provincial transportation agencies now only require NVOCCs to provide a few basic details identifying the company and a contact individual.”

The ”deregulation” eliminates the need to provide “articles of incorporation, letters of entrustment, feasibility studies, agency agreements or to have any of these documents consularized,” the NCBFAA said in July. The registrations are now to be done online, and to be filed with the provincial authority where each NVOCC does business. “As we understand it, there is no need for multiple filings and that each NVOCC's agent can take care of this process,” the NCBFAA said.

“It accordingly appears that all NVOCCs wishing to either use their house bills of lading for traffic into and out of China now must either register or re-register to do so,” the trade group’s July update said. “For this purpose, you will need to contact your Chinese agents to initiate this new registration process.”