The U.S. 50% ownership rule is coming! Cross-border e-commerce payment compliance + stable logistics, this article is all you need.
Created on 10.10
On September 29, 2025, the U.S. Department of Commerce issued export control penetration rules, incorporating global subsidiaries of companies listed on the "Entity List" under the "50% ownership penetration principle," affecting thousands of enterprises across nearly a hundred countries and regions. This policy directly impacts the industrial chain cooperation between China and ASEAN — it is worth noting that ASEAN has been China's largest trading partner for several consecutive years, with bilateral trade reaching $982.335 billion in 2024, and China's export growth to ASEAN (12.0%) far exceeding that of the European and American markets. For cross-border e-commerce relying on the "China supply - ASEAN assembly - global export" model, the compliance of payment links and the stability of logistics face dual challenges.
Three Core Influences: Risk Points in Cross-Border E-Commerce That Cannot Be Ignored
1. Payment compliance risks: "Penetrating review" becomes a new threshold for collections.
The new regulations shift the due diligence responsibility to exporters, requiring companies to conduct thorough checks on the ownership structure of their trading partners to avoid associations with regulated entities. This has a direct impact on cross-border e-commerce payments:
- Traditional bank wire transfers require the submission of complete equity certificates and transaction documents, otherwise, it may trigger a fund freeze;
- Third-party payment platforms (such as PayPal, Wanlihui, etc.) strengthen transaction background checks, and orders with "three flows inconsistent" (contract, logistics, and capital flow mismatch) are likely to be rejected.
- Some enterprises have seen a sharp increase in risks associated with the personal account collection model. The Golden Tax Phase IV system has implemented penetrating supervision of public-to-private transactions, and such operations may face tax payment arrears, late fees, and even criminal liability.
2. Logistics chain risk: The integration model of the industrial chain encounters obstacles
The core of "Made in China - ASEAN Export" is the deep collaboration of "China supplying components + ASEAN assembling," with countries like Vietnam and Malaysia being the main processing bases. Under the new regulations:
- If upstream component companies are listed on the control list, their ASEAN assembly plants with more than 50% shareholding will also be restricted, leading to interruptions in goods production;
- Exporters need to additionally verify the equity structure of all participants in the logistics chain (such as freight forwarders and warehousing companies) to increase the risk of delays in the shipment of goods.
3. Regional Customs Clearance Risks: Dual Pressure of Timeliness and Cost
Despite the fact that hubs like Nanning have reduced the cross-border e-commerce customs clearance time to 1 hour, under the new regulations:
- The customs has strengthened the inspection of goods related to enterprises on the "Entity List," and the clearance period for ordinary goods may be extended;
- Companies need to prepare additional documents such as equity structure explanations and non-control declarations, resulting in a significant increase in compliance costs.
Zhongnan Whale Navigation Solutions: Safeguarding Compliance for Overseas Ventures with Professional Logistics Capabilities
1. Full-chain compliance support, matching payment verification requirements
Leveraging 20 years of international logistics experience, we can provide our clients with:
- Provide a complete logistics document chain (bill of lading, packing list, storage receipt, etc.), ensuring "three flows consistency" with the payment process, and reducing the risk of chargebacks from third-party payment platforms;
- Assist in sorting out the sources of goods and the proof of the production chain, helping to cope with the penetrating review by customs and payment institutions.
2. Flexible logistics network to respond to fluctuations in the industrial chain
- ASEAN Link Assurance: With a service network covering over 100 countries and regions worldwide, it can quickly switch transportation channels such as the China-Vietnam train and Beibu Gulf shipping, in conjunction with the "Smart Customs Clearance" system at hubs like Nanning, to shorten the transit time of goods;
- Overseas warehouse emergency buffer: Overseas warehouses in the United States, Canada, and other locations can achieve advance stocking of goods. If there are obstacles in the processing links in ASEAN, goods can be directly shipped one by one from the overseas warehouse, avoiding order loss.
3. The advantages of the nationwide dedicated line ensure terminal delivery.
For the core U.S. market of cross-border e-commerce, our nationwide full container DDP/DDU service can achieve "door-to-door" full control. With 30 self-owned trailers and 65 chassis resources available for flexible scheduling, we ensure efficient delivery of goods under compliance.
The new U.S. export control regulations have pushed "Made in China - ASEAN exports" into a new phase of "compliance is king," where payment security and logistics stability have become the key to survival in cross-border e-commerce. Zhongnan Whale Shipping, with 20 years of professional experience, a global warehousing and distribution network, and flexible transportation resources, can provide customers with compliant logistics documents that match payment verification requirements, while also mitigating supply chain volatility risks through multi-channel transportation and overseas warehouse layouts. In the ever-changing environment of going overseas, a professional logistics partner is not only a compliance "firewall" but also a business "stabilizer."
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