DFDL Cambodia

On 4 July 2025, the General Department of Customs and Excise has issued Instruction 3133/25 to modernize and streamline customs clearance procedures, with a particular emphasis on customs transit operations. This new instruction introduces enhanced operational standards, clearer compliance obligations, and simplified procedures for authorized operators.

On 4 July 2025, the General Department of Customs and Excise (“GDCE”) has issued Instruction 3133/25 (“Instruction 3133”) to modernize and streamline customs clearance procedures, with a particular emphasis on customs transit operations. This new instruction introduces enhanced operational standards, clearer compliance obligations, and simplified procedures for authorized operators.

Instruction 3133 expands on the regulatory framework established by Prakas 508 (in 2008) on customs transit and Prakas 788 (in 2023) on pre-arrival customs formalities. It repeals and replaces Instruction 790 dated 28 August 2008 and Instruction 1090 dated 17 October 2008, along with any other provisions that conflict with the new directive.

The updated procedures will take effect from 1 August 2025, and all relevant stakeholders are expected to comply accordingly.

A. Scope and Eligible Operators

Instruction 3133 applies to both domestic (import) and international transit, with international operations subject to Cambodia’s treaty obligations. Only legally authorized entities may operate under customs transit procedures, including:

  • Temporary customs warehouse operators,
  • Hotel operators with limited customs duties, and
  • Individuals with prior GDCE approval.

B. Guarantee Requirement

Transit operators must deposit a security guarantee at GDCE’s Accounting Office in accordance with applicable laws. Deposits at departure customs offices are not accepted. The minimum deposit is regulated and may be adjusted at GDCE’s discretion to ensure financial accountability.

C. Means of Transport Through Customs

Customs transit is permitted for the following types of transport:

  • Containers: Must be sealable, durable, reusable, and designed for efficient multi-modal transport with a minimum internal volume of one cubic meter.
  • Other Vehicles: Must allow secure sealing, prevent unauthorized access or concealment, and enable easy inspection by customs officials.
  • Unsealed or Oversized Goods: May be allowed if clearly identifiable through physical inspection, parcel-level sealing, or detailed documentation such as sketches or photographs.

Customs officials are authorized to monitor and prevent tampering or unauthorized changes during transit.

D. Prohibited Transit Goods

Goods prohibited from customs transit include those restricted by Cambodian law, banned under international agreements, or specifically designated by the GDCE.

E. Transit Operator Responsibilities

Transit operators must ensure full compliance with customs procedures, including accurate documentation, secure transport, and cooperation with customs officials.

  • Customs Clearance: Applications must follow the prescribed format as per Appendix “C” of Instruction 3133 and include required electronic documents. Requests for goods entering SEZs go to the SEZ Customs Office; others go to GDCE. Pre-arrival clearance is allowed, and operators must manage updates, corrections, or cancellations through the approving entity.

  • Departure Procedures: For customs transit into a SEZ located within 20 kilometers of the entry point, the transit operator or representative must present the approved transit request to customs officials at the departure office. In these cases, a transit declaration is not required. For other cases, operators must submit electronic documents, complete pre-arrival formalities, and receive electronic receipts. If inspection is required, they must coordinate with relevant offices. Once transport is approved, electronic payment is processed and a voucher is issued, which is valid for a single leg of the journey.
  • Shipping Compliance: Transit operators or their representatives are responsible for ensuring that goods are transported in strict compliance with customs transit procedures. Goods must follow the approved route and schedule. No alterations or tampering are allowed. Changes in transport or route must be system-approved. In case of accidents, goods may only be accessed with customs officer approval unless safety is at risk.
  • Customs Office Coordination: For international transit, import declarations may be filed pre-arrival. Operators must present documents at both departure and destination offices and participate in inspections if required.

F. Duties of Customs Officers

Customs officers are responsible for ensuring compliance, accuracy, and integrity throughout the customs transit process. Their key duties include:

  • Transit Request Review: Officers must verify the completeness and consistency of submitted requests, request additional documents if needed, and return or reject applications with clear instructions when irregularities are found. Approved requests are forwarded to management.
  • Departure Office Oversight: Officers inspect transit documents (except for SEZs within 20 km), verify goods and declared fees, record inspection outcomes, and coordinate with scanning or inspection teams. They also track pending transit operations daily and follow up on overdue cases.
  • Physical Inspection: Officers validate transport documents, match them with actual goods, apply customs seals, and ensure system data accuracy. For high-risk or flagged goods, inspections must be conducted by at least two officers with the operator present.
  • Payment Handling: Officers oversee tax and fee payments via electronic systems, bank transfers, or cash, and issue receipts without requiring signatures. Refunds must follow legal procedures.
  • Destination Office Duties: Upon arrival, officers confirm transport entry, investigate delays over three days, inspect seal integrity, and conduct physical inspections if needed. Any violations must be documented in a customs violation report under the applicable laws.

G. Simplified Customs Transit Procedures

Authorized Economic Operators (AEOs) and individuals approved by GDCE may benefit from simplified customs clearance, including the use of special seals and the ability to clear goods at their premises.

Transit operators must notify consignees upon arrival. If no prior approval exists, consignees may proceed independently but must report irregularities. If permission is denied, clearance must wait for customs officials. The consignee is fully responsible for compliance.

The Customs and Excise Administration Unit oversees these procedures by verifying authorized transit operations, responding to consignee requests, and dispatching at least two officers when official presence or inspection is required.

Conclusion

Instruction 3133 marks a significant step forward in modernizing Cambodia’s customs transit framework. By introducing clearer procedures, defined responsibilities, and streamlined processes (particularly for authorized operators), the instruction aims to enhance operational efficiency, reduce compliance risks, and align with international best practices.

Businesses engaged in import, export, or transit activities should carefully review the new requirements and ensure their internal procedures are updated accordingly ahead of the 1 August 2025 implementation date. Early preparation and compliance will be essential to avoid disruptions and to benefit from the efficiencies introduced under this new regulatory framework.

Tax services required to be undertaken by a licensed tax agent in Cambodia are provided by Mekong Tax Services Co., Ltd, a member of DFDL and licensed as a Cambodian tax agent under license number – TA201701018.

Clint O'ConnellPartner, Managing Director, Cambodia

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DFDL Cambodia

DFDL established its headquarters in Cambodia in 1995. DFDL is licensed as an investment company by the Council for the Development of Cambodia and the Cambodian Investment Board. We are also registered as a private limited company with the Ministry of Commerce. Under these licenses and registrations, we are permitted to provide business consulting, tax and investment advisory service of an international nature.

On 1 March 2016, DFDL and Sarin & Associates joined forces and established a commercial association and cooperation in order to form a new business transactions platform to serve clients with interests in Cambodia and across the expanding ASEAN marketplace.

DFDL and Sarin & Associates have worked together for over 10 years in Cambodia. Sarin & Associates has long been recognized for providing advice to companies in Cambodia in several sectors, such as telecommunication, energy, retail, real estate, financial services, banking, etc.

Our clients are major international and Asian foreign investors in Cambodia, including large foreign and Asian financial institutions. We have been involved in major projects in Cambodia including electricity projects, aviation, telecommunications, infrastructure projects and large real estate projects.

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