A distributor or service partner outside China is about to send one ultrasound system, board, or probe to a repairer inside a Chinese comprehensive bonded zone and needs the goods back. The commercial invoice often says only "ultrasound." On the instruments in force on 28 September 2026, that word sits on two 10-digit codes with different catalogue treatment, and on three sentences in one announcement with different subjects.
The pre-alert has four lines: the declared code, whether the goods are the repairing enterprise's own group's products, which paragraph is being claimed, and which destination declaration is still missing. The 23 September 2026 shipping report covers the planning calendar, and it records that a Huangpu approval leaves the buyer's border to the buyer's own entry. This article is the code and the paragraph.
Two ultrasound codes are two catalogue rows
The fourth-batch workbook shows its own columns, the way it writes a parts line, and the character a search has to match before serial 148 appears.
The fourth-batch file is the catalogue paragraph 1 incorporates. Its sheet runs A1:C183. The header row is 序号, 商品编码, 产品名称. There is no 备注 column. A count of the commodity-code column on 28 September 2026 found 179 unique 10-digit codes. The closing note says 商品编码根据海关商品编码变化动态调整: commodity codes are adjusted dynamically as customs codes change. The rows below are the codes in this file, at the date it was read, and the note itself reserves a later renumbering. 2
The Hong Kong Trade and Industry Department's Commercial Information Circular No. 15/2026 reprints the announcement as an excerpt from the same MOFCOM page and prints annex 1 serial 148 as 9018121000 Ｂ型超声波诊断仪. The circular prints no row for 9018129110. 5
| Fourth-batch annex, 16 December 2025 | 2021 supplementary catalogue, 24 December 2021 | |
|---|---|---|
| Code | 9018121000 | 9018129110. The same remarks also sit on row 10, which is 9018121000. |
| Name as printed | Ｂ型超声波诊断仪. The first character is the fullwidth letter Ｂ. | 彩色超声波诊断仪 on row 11. Row 10 prints B型超声波诊断仪 with a halfwidth B. |
| Place in the file | Serial 148 | Row 11 |
| Columns | 序号, 商品编码, 产品名称 | 序号, 商品编码, 产品名称, 备注 |
| Remark on the ultrasound row | No remarks column, so serial 148 carries no group-production remark | 暂限于综合保税区内开展集团自产产品维修 |
| Sentence that uses the row | Paragraph 1: a zone enterprise may conduct repair of the products in annex 1 | The sentence after paragraph 1 of Announcement 2021 No. 45, quoted below |
The 2021 body sentence is wider than the cell, and it is still the sentence on the page:
目录中B型超声波诊断仪、彩色超声波诊断仪、无创呼吸机等产品暂限于综合保税区开展集团自产产品的保税维修
Rendering: B-mode ultrasonic diagnostic equipment, color ultrasonic diagnostic equipment, non-invasive ventilators, and similar products in that catalogue are for the time being limited to bonded repair, inside the comprehensive bonded zone, of the group's own products. 3
The remarks cell on rows 10, 11, and 12 uses a shorter string of the same limit, 暂限于综合保税区内开展集团自产产品维修. Row 12 is the non-invasive ventilator named in the body sentence. 4 The body says 保税维修 and 综合保税区. The cell says 维修 and 综合保税区内. Both record a temporary limit to the group's own products.
The same presence check that found 9018121000 returned no match for 9018129110, and no match for the nearby residuals 9018129190, 9018129900, 9018129990, and 9018199090. The only 901812 code in the 179 is 9018121000 at serial 148. 2 Color ultrasound stays on its own 2021 row. Treating every 901812 residual as serial 148 would rename a color system as Ｂ型超声波诊断仪.
The workbook writes a parts line when it wants one: serial 150, 9018139000, 核磁共振成像装置用零件; serial 153, 9018193090, 病员监护仪的零件及附件; serial 160, 9018909991, 电子的其他医疗、外科用仪器器具的零件及附件; serial 161, 9019201010, 有创呼吸机（整机）, beside serial 162, 9019201090, 有创呼吸机的零件及附件; and serial 163, 9021400000, 助听器,不包括零件、附件. 2 No product name on a 9018 row contains 探头. Serial 148 names the B-mode instrument, and the parts formula and the "excluding parts" formula appear on the rows just listed.
The first-batch workbook attached to Announcement 2020 No. 16 has a single line whose name contains 超声, serial 14 under heading 8456 for machine tools, and no 9018 diagnostic-ultrasound code. 6 The 2025 cell and the Hong Kong excerpt print a fullwidth Ｂ (U+FF22), while the 2021 body and row 10 use a halfwidth B, so a halfwidth-only search misses serial 148 even when 9018121000 sits in the code column. 2 5
Three sentences in Announcement 2025 No. 82
Paragraph 1's verb is 可开展, paragraphs 2 and 3 each name the repairing enterprise's own group, and paragraph 5 is the conflict rule the announcement itself supplies.
Paragraph 1 names the examples, then points at the annex:
综合保税区内企业（以下简称区内企业）可开展通信基站、铁道机车、游艇、汽车动力电池等产品的维修业务（维修产品目录见附件1）。
Rendering: a zone enterprise, 区内企业, may conduct repair of products such as communication base stations, railway locomotives, yachts, and automotive power batteries. The repair-product catalogue is annex 1. 1
The verb is 可开展, may conduct. The subject is the zone enterprise. The four examples introduce the annex, and serial 148 sits inside that annex.
Paragraph 2:
允许区内企业开展本集团国内自产并出口至境外的机电产品“两头在外”保税维修业务，不受综合保税区维修产品目录和禁止进口的旧机电产品目录限制（机电产品范围见附件2）。
Rendering: zone enterprises are permitted to conduct both-ends-outside bonded repair of electromechanical products that their own group produced in China and exported. That route proceeds free of the repair-product catalogues and free of the catalogue of prohibited used electromechanical products. The product scope is annex 2. 1
Paragraph 3:
允许区内企业开展本集团在全球范围内生产并在国内完成销售产品的保税维修业务，维修后返回国内或直接出口至境外。
Rendering: zone enterprises are permitted to conduct bonded repair of products the group produced worldwide and whose sale was completed in China. After repair, the goods are returned domestically or exported directly. 1
Both paragraphs use 允许, are permitted, and both use 本集团, the repairing enterprise's own group. Paragraph 2 is China production plus export, both ends outside, and the catalogue waiver is written there. Paragraph 3 is worldwide production plus a sale completed in China, with domestic return or direct export. Paragraph 3 leaves that waiver unwritten. The waiver stays where paragraph 2 wrote it.
Annex 2 is titled 机电产品范围（适用于国内自产出口产品保税维修）, the electromechanical scope for bonded repair of domestically produced exported products. Its code cell includes the range 82-91, so heading 9018 sits inside the published scope. A note says the scope adjusts with the customs statistical scope. 7 The Hong Kong excerpt prints the same range. 5 A group-made, China-exported ultrasound system can therefore sit inside paragraph 2's product scope when its 10-digit code lies outside annex 1. 本集团 remains a condition of the paragraph. An independent shop repairing another manufacturer's system falls outside that condition.
Paragraph 5 is the conflict rule:
涉及综合保税区内维修业务的其他事项按照商务部、生态环境部、海关总署公告2020年第16号、2021年第45号、2024年第7号等公告执行。上述文件相关内容如与本公告不符，以本公告为准。
Rendering: other repair matters inside comprehensive bonded zones follow Announcements 2020 No. 16, 2021 No. 45, and 2024 No. 7. Where those documents conflict with this announcement, this announcement prevails. Paragraph 6 makes No. 82 effective on the date of issue, 16 December 2025. 1
Paragraph 5 keeps the earlier announcements. The text contains no sentence cancelling the temporary group-production limit on B-mode ultrasonic diagnostic equipment.
Set side by side, the pages leave two paperwork positions, and a project approval can be narrower than the national catalogue. For a complete instrument declared as 9018121000, the pre-alert cites paragraph 1 and serial 148 and keeps the 2021 B-mode sentence in the file. Paragraph 5 supplies the conflict rule and contains no cancellation of that sentence, so whether the remark-free listing conflicts with the 2021 sentence is the question the two pages create. For 9018129110, row 11 remains the text that names the code.
Two earlier group sentences are still printed, and each has its own goods. Announcement 2021 No. 45, paragraph 5, permits enterprises in comprehensive bonded zones inside pilot free-trade zones to repair the group's own domestically produced products, and it places that repair free of the repair-product catalogue. 3 Announcement 2024 No. 7, issued and effective on 29 February 2024, paragraph 2, permits a zone enterprise to repair the group's own products sold in China and to return them to the domestic market, and it places that route free of the repair-product catalogue. Paragraph 3 permits catalogue goods already inside China to enter a zone for repair and then be exported. Paragraph 5 of No. 7 keeps the 2020 and 2021 announcements except where they conflict with No. 7. 8
A China-produced, China-sold group product is 2024 paragraph 2 when the return is domestic, and it is also readable against 2025 paragraph 3 when the group produced the goods worldwide, the sale was completed in China, and the goods may return domestically or be exported. A China-produced export is paragraph 2 of No. 82. The pre-alert has to carry the production and sale facts. "Same-group route" alone matches none of the three sentences.
Shanghai's rules, 沪商贸改〔2026〕184号, issued on 6 July 2026, cite Announcements 2020 No. 16, 2021 No. 45, 2024 No. 7, and 2025 No. 82 and notice 276 in the opening of the document. Article 1 then says zone enterprises conduct bonded repair according to the national policy and the repair-product catalogues. The rules name no ultrasound code and no company. 9 Following the catalogues, and keeping group repair inside the group, is already that article. The 2021 announcement treated the two ultrasound codes as one limited pair. The increment on 28 September 2026 is the remark-free 2025 row for 9018121000 beside the 2021 row for 9018129110, which lies outside the 179-code workbook.
Sort one shipment before it leaves
Four lines, filled from the invoice and from the production and sale facts, decide which sentence is being claimed before the box is sealed.
- Declared 10-digit code, copied from the commercial invoice, and the catalogue row that prints it.
- Whether the goods are the repairing enterprise's own group's products, and which facts are relied on: China production and export, worldwide production with the sale completed in China, or neither.
- The paragraph claimed: paragraph 1 of Announcement 2025 No. 82, the 2021 group-production remark, paragraph 2, paragraph 3, or the 2024 domestic-sale sentence.
- The destination declaration still missing. The China paragraph leaves this line blank.
The illustrative rows below use stated inputs so the form can be read against the instruments. They record no shipment, and they say nothing about how often a zone accepts or refuses a box.
| Stated input | Code and row | Own group's products? | Paragraph that matches | Destination line |
|---|---|---|---|---|
| Complete instrument, invoice 9018121000, description Ｂ型超声波诊断仪. Independent zone enterprise. Goods come from outside China and go back. | Serial 148. No group-production remark. | No | Paragraph 1, if that enterprise's project approval covers the repair. Keep the 2021 B-mode sentence in the file. | Open until the shipper names the customs territory the goods left. |
| Complete color instrument, invoice 9018129110. Same independent enterprise. | 2021 row 11, remark 暂限于综合保税区内开展集团自产产品维修. Outside the 179 codes. | No | None of paragraphs 1, 2, or 3 on these inputs. | Leave it. The China route stays unestablished on these inputs, so the home entry waits. |
| The repairer's own group produced the goods in China and exported them. Any invoice code under the annex 2 scope, including 9018129110. | The invoice code. Heading 9018 is inside the range 82-91. | Yes | Paragraph 2. The repair catalogues and the prohibited-used catalogue leave this route free of those lists. | Still open. |
| The repairer's own group produced the goods worldwide and the sale was completed in China. | The invoice code. | Yes | Paragraph 3, which writes no catalogue waiver of its own. Where the facts are narrower, domestic production, a domestic sale, and a domestic return, 2024 paragraph 2 does lift the repair-product catalogue. | Still open, and the direction of travel has to match the paragraph used. |
| Loose board or probe. The invoice has a part number. The shipper proposes 9018121000 because the part left a B-mode system. | Serial 148 names the instrument. No 901812 parts line is printed. No 9018 name contains 探头. | No | No ultrasound row in this workbook names that piece. | Classification sits outside the file. |
A code other than 9018121000 falls outside serial 148. Where the repairer is the manufacturer's group and the goods were produced in China and exported, paragraph 2 can be the sentence even when the code lies outside annex 1. 1 2 Putting 9018129110 on the B-mode row because both machines are ultrasound would name a color system as Ｂ型超声波诊断仪. Those goods move to paragraph 2, paragraph 3, or 2024 paragraph 2 when the enterprise is that group and the production and sale facts match the sentence. 4 7 8 A loose board or probe may be classifiable as 9018121000, as 9018909991, or under another heading. Until a notice 276, section 4, pilot exists for that piece, it stays off the paragraph 1 product list. The instruments read here include no public Huangpu pilot approval for an ultrasound parts code. 2 10
What an open route still requires
A catalogue row still waits on the enterprise's project approval, on the accounts the notice requires, and on the direction of travel the matching sentence names.
The enterprise's own permission stays where the 2020 announcement put it. Paragraph 3 of Announcement 2020 No. 16 says the zone authority, together with local commerce, customs, and other departments, jointly studies and decides the repair business and draws up a supervision plan. The plan and the enterprise list are filed with the provincial commerce department, the regional customs, and other departments. 6 Shanghai's article 4 requires the application to include operating procedures, a customs-compliant management system and information system, safety rules, and a pollution-control plan. Article 5 has the local authority examine the application and write the project supervision plan. 9 Serial 148 can sit on the national annex while a particular enterprise's approval is narrower, or while that approval is still pending.
Paragraph 4 of Announcement 2025 No. 82 requires compliance with Shangban Mao Han [2025] No. 276, the offices' notice of 26 March 2025, and an ERP networked with customs and the other departments. The zone authority, with commerce, ecology, and customs, runs full-chain supervision, and the province reports projects that start, pause, and end. 1 Section 5 of the notice says the ERP transmits data to customs and tracks consumption. The enterprise keeps separate accounts for goods already repaired, goods awaiting repair, goods for which repair has failed, materials, old or bad parts taken off during repair, and offcuts. 10 Decree 256, article 6, is the customs rule beside that duty: customs applies computer-networked administration to zone enterprises. 11
The direction after repair follows the sentence that matches the goods' origin. Announcement 2020 No. 16, paragraph 2, allows repair of goods from abroad or from inside China outside the zone, requires repaired goods to be shipped back according to their origin (应根据其来源复运至境外或境内区外), and says enterprises may not use repair to conduct dismantling or scrapping (不得通过维修方式开展拆解、报废等业务). 6 Notice 276, section 5, says products repaired after entry must be shipped back abroad and, unless a relevant rule permits it, may not be sold or used in China (进境维修后产品须复运出境，除有相关规定准许外，不得入境销售、使用). 10 Two later sentences are the kind of rule that clause points at. Announcement 2024 No. 7, paragraph 3, covers catalogue goods already in China that will be exported after repair. Paragraph 3 of No. 82 covers the group's own products whose sale was completed in China. A customer's system that entered from abroad under paragraph 1 follows the 2020 origin rule and the notice 276 re-export rule.
Old parts carry a stop date. Announcement 2020 No. 16, paragraph 5, says offcuts, old parts, and bad parts from inbound repair should in principle all go back abroad; what truly has no route back may not be sold in China and is destroyed, and failure to dispose of them within the supervision-plan period should end the bonded-repair business. 6 Shanghai's article 2 says that same failure terminates the business, and that restarting requires a new application. 9 During rectification, Announcement 2024 No. 7, paragraph 4, says the enterprise may not conduct bonded repair until the zone authority accepts the result, and notice 276, section 6, pauses new bonded-repair projects for the same period. 8 10 Importing solid waste in the name of repair is forbidden by the notice and by Shanghai's article 3, and Decree 256, article 22, sends solid waste that stays in China to the domestic solid-waste rules. 10 9 11
Notice 276, section 2, reserves a brand-owner or agent authorization for a separate pilot covering aircraft, ships, tunnel-boring machines, and similar large equipment, while paragraph 1 of Announcement 2025 No. 82 reaches an independent zone enterprise through an annex 1 row and that enterprise's project approval. 10 1 Section 4 of the same notice is the pilot for products outside the catalogue and for repair outside the listed zones: the province assesses the project, writes a supervision plan, and reports it to the Ministry of Commerce, which decides with the Ministry of Ecology and Environment and the General Administration of Customs. 10
Decree 256, article 7, and Announcement 2020 No. 16, paragraph 1, keep state-prohibited goods out of movement between the zone and abroad, and out of the repair business, unless a law or an authorized rule permits them. 11 6 Announcement 2021 No. 45, paragraph 2, permits repair of prohibited used electromechanical products that are listed in a repair catalogue, where environmental protection and work safety are met. 3 Paragraph 2 of No. 82 lifts the prohibited-used catalogue for the group's own China-produced exports. 1 Where a license applies, paragraph 4 of the 2021 announcement requires a truthful declaration and presentation of the license at entry, exit, or the zone boundary. 3
Bonded status in the zone, and the return declaration
Article 11 bonds goods that enter the zone from abroad, and the declarations on the way home are 19 CFR 10.8 or Articles 203 and 158, according to the territory the goods left.
Decree 256 is the customs administration of the zone, promulgated on 1 January 2022, effective on 1 April 2022, and amended on 28 October 2024. Article 5 says zone enterprises may, in accordance with law, conduct businesses that include testing and repair. Article 9 says the consignee or agent of goods moving between the zone and abroad declares truthfully and files the entry-exit record list. Article 11 says goods entering the zone from abroad are bonded (予以保税), except for the cases in articles 12 and 14. 11
Article 12 is an exemption from import duty and import-stage tax, and the list is specific. It covers infrastructure materials and the machinery and equipment for productive infrastructure, the machinery, equipment, moulds, and their repair parts that the zone enterprise uses to carry out the article 5 businesses, and a reasonable quantity of office supplies for the zone administration and the enterprise. 11 A customer's ultrasound system, sent in for repair and due to leave again, is the bonded case in article 11. The enterprise's own machine is the article 12 case. Article 14, the other exception article 11 names, stays outside this description.
Rongtao Medical's company news of 28 July 2026 says that equipment in its bonded cycle pays no import duty or import VAT. 12 That is the company's description of its China cycle, which is the article 11 bonded case for goods entering from abroad. The article 12 exemption and the duty a destination authority charges when the goods go home are separate matters. The September shipping report already says that the approval page adds no tax rate. 13 The destination packet depends on which customs territory the goods left.
A system that was exported from the United States
19 CFR 10.8 is the provision for articles exported from the United States for repair or alteration when the importer claims duty only on the value of the repairs or alterations under HTSUS subheading 9802.00.40 or 9802.00.50. The text used here is the Cornell Legal Information Institute copy of that section. 14
The person who performed the repair declares that:
- the articles were received in the condition in which they were exported from the United States;
- they were received for the sole purpose of repair or alteration;
- only the described repairs or alterations were performed;
- the full cost or value of that work is stated;
- no substitution was made.
The importer declares that the articles were exported from the United States for repairs or alterations without drawback, and that the articles being returned are the same articles. The Center director may require proof of the US export. Estimated duties are deposited on the full cost or value of the repairs or alterations actually performed abroad, including the articles furnished for the repair. 14
No percentage is stated here. The repairer's declaration and the importer's declaration are the documents the section names. A Huangpu project approval is a different document. A system never exported from the United States falls outside the section as written.
A system that was exported from the European Union as Union goods
On 28 September 2026 the returned-goods rule read for this article is Regulation (EU) No 952/2013, Article 203, in the EUR-Lex consolidated text of 12 December 2022. Article 203(1) says that non-Union goods which were originally exported as Union goods from the customs territory of the Union, which are returned to that territory within three years, and which are declared for release for free circulation, are granted relief from import duty on application by the person concerned. The same paragraph says the relief applies even where the returned goods are only a part of the goods previously exported. Article 203(2) says the three-year period may be exceeded to take account of special circumstances. Article 203(3) says that if, before export, the goods had been released duty-free or at a reduced rate because of a particular end-use, the relief is granted only if they are released for the same end-use. Article 203(5) says the relief is granted only if the goods are returned in the state in which they were exported. Article 203(6) says the relief is supported by information establishing that the conditions are fulfilled. 15
Commission Delegated Regulation (EU) 2015/2446, Article 158, is the provision that says what "the state in which they were exported" allows. Article 158(1) treats goods as returned in that state where, after export, they have received no treatment other than treatment that alters their appearance, or treatment necessary to repair them, restore them to good condition, or maintain them in good condition. Article 158(3) says that where the treatment would have made the goods liable to import duty if they had been placed under outward processing, they are considered returned in the same state only where the treatment, including the incorporation of spare parts, stays within what is strictly necessary to enable the goods to be used in the same way as at the time of export. 16
Article 158 supplies no grade for a particular ultrasound board against "strictly necessary," and Article 203(6) requires information establishing that the conditions are fulfilled. The zone approval supplies none of that information, and the articles name no ultrasound form.
Hong Kong TID Commercial Information Circular No. 816/2026, dated 21 September 2026, says Regulation (EU) 2026/2108 was published on 19 September 2026, repeals Regulation (EU) No 952/2013, entered into force on 20 September 2026, and will apply from 21 September 2027, except for specified provisions on the EU Customs Data Hub and e-commerce. 17 For a return on 28 September 2026, Article 203 of the 2013 code remains the returned-goods rule those dates leave in application. A system exported from neither territory falls outside both provisions as written.
What Rongtao's Huangpu approval covers
The 28 July 2026 announcement states the company's own project, and a partner with a color system, a loose board, or a probe asks which route applies before the goods move.
Guangzhou Rongtao Medical Technology Co., Ltd. published company news on 28 July 2026 saying the company received government approval to operate bonded repair of B-mode ultrasound diagnostic equipment at its headquarters in the Huangpu Comprehensive Bonded Zone, after review of management systems, a customs-linked information platform, and environmental controls. The workflow sentence tells customers to ship faulty B-mode ultrasound equipment. The same announcement invites customers who have systems, boards, or probes to ask the team for a quote and for shipping instructions. 12
The national annex lists 9018121000, serial 148, Ｂ型超声波诊断仪, for a zone enterprise. 2 1 A statement that an approval covers B-mode ultrasound diagnostic equipment matches that product name. For a color system, or for a loose board or probe, a partner should ask Rongtao, before shipping, which route and which documents apply to that item. The quote and shipping desk is the contact page, and the published address is info@rongtaomedical.com.
What this comparison leaves open
These limits sit in one place, because each one changes what a pre-alert can claim.
This article relies on no classification ruling for a loose board or a loose probe. The prohibited-used catalogue remained outside the reading, so this article places neither 9018121000 nor 9018129110 on that list and records neither code as absent from it. 3 1 The government approval document behind the 28 July 2026 announcement was not available for this article. 12 The third-batch annex to Announcement 2024 No. 7 stayed without a machine-confirmed code reading, so the ultrasound comparison uses the paragraphs of No. 7 and leaves that annex aside. 8 The two .wps attachments to notice 276, including the free-trade-zone repair catalogue, stayed unread, so their product lists stay undescribed. 10 The figure 179 is a count of catalogue codes in the workbook paragraph 1 incorporates; approved enterprises are recorded elsewhere.
Frequently asked questions
Does a loose probe use serial 148?
Serial 148 is 9018121000, Ｂ型超声波诊断仪. The fourth-batch workbook gives parts their own lines when it lists them, at serials 150, 153, 160, and 162, and serial 163 names hearing aids as excluding parts and accessories. No 9018 product name contains 探头. A loose probe sits outside those rows. Classifying it is a separate question, and notice 276, section 4, is the pilot path for a product outside the catalogue. 2 10 Ask Rongtao which route and which documents apply before that piece ships.
Is the Huangpu approval the US or EU repair entry?
The 28 July 2026 company news says Rongtao Medical holds a government approval to operate bonded repair of B-mode ultrasound diagnostic equipment in the Huangpu Comprehensive Bonded Zone. 12 A US return under 19 CFR 10.8 still needs the repairer's declaration and the importer's declaration when the claim is HTSUS 9802.00.40 or 9802.00.50. 14 An EU return under Article 203 still needs the application, the same-state condition in Article 158, and information establishing the conditions, for goods exported as Union goods. 15 16 The Huangpu approval is a different document. The September 2026 shipping report is the companion on timing and on the buyer's border. 13
Before the box leaves
The pre-alert has four lines. The declared 10-digit code, copied from the invoice, and the catalogue row that prints it. Whether the goods are the repairing enterprise's own group's products, with the facts relied on: China production and export, worldwide production with the sale completed in China, or neither. The paragraph claimed. The destination declaration still missing, from 19 CFR 10.8 or from Article 203 and Article 158, according to the territory the goods left. For a color system, a loose board, or a loose probe, ask Rongtao which route and which documents apply before the goods ship: rongtaomedical.com/contact, or info@rongtaomedical.com.