ICBC: the importer’s repayment test for Canadian pea starch

This spotlight uses Industrial and Commercial Bank of China (ICBC) as a hypothetical importer-side lender to examine one question: how would a Chinese buyer repay borrowing while its customs deposit remains committed? The exercise does not assume an ICBC lending programme, customer relationship or arrangement with a Canadian exporter’s bank.

The funding requirement is concrete. China’s preliminary measure requires a deposit on covered Canadian-origin unmodified pea starch from July 1, 2026, at a rate of 73.5% for all Canadian companies.^[1] The cited measure establishes the customs requirement and leaves the final outcome undetermined; it does not establish financing for the deposit.^[1] For an importer considering an approach to ICBC, the proposed assessment therefore starts with the transaction’s cash needs, rather than an expectation of available credit.

The amount to be financed needs careful definition. The specified deposit equals customs-assessed taxable value multiplied by 73.5%, then by one plus the import VAT rate.^[1] An importer approaching a prospective lender could present the merchandise payment and customs deposit separately, alongside other transaction outlays. Using only 73.5% of the supplier’s invoice would omit the VAT factor and assume that invoice value equals the customs-assessed taxable value.^[1] The useful starting point is a documented funding requirement, with valuation and applicable VAT inputs identified.

The more consequential question is what repays the borrowing. China extended the investigation to February 12, 2027, citing the case’s complexity.^[2] Neither that extension nor the preliminary measure establishes a deposit-release date or the final outcome.^[2][1] A prospective ICBC assessment could ask whether repayment would come from selling the imported starch, the importer’s wider operating cash flow or an assumed deposit refund. Those are different propositions. If repayment depends on a refund, the proposal could identify that dependency explicitly, without presenting the investigation deadline as a cash receipt.

For the importer, this suggests preparing evidence of expected customer receipts, existing payment obligations and liquidity available if deposit settlement takes longer than expected. For a prospective lender, the question would be whether the business could carry the transaction without repeatedly extending short-term borrowing. These are proposed assessment questions, not a description of ICBC’s underwriting rules. In this hypothetical transaction, payment to the Canadian seller could be completed while the importer still needed to finance the deposit. Exporter collection and importer repayment would therefore require separate tests.

Product scope also matters to the proposed assessment. Specified Canadian peas benefit from suspension of the additional 100% tariff through December 31, 2026, while covered pea starch faces the separate provisional deposit.^[3][1] An enquiry could identify the actual product and origin before using either treatment in a cash-flow forecast. The suspension for specified peas provides no basis for treating covered starch as exempt from its deposit requirement.^[3][1] Any comparison of the two purchasing options would also need a separate commercial assessment.

Canada and China launched a Financial Working Group in April 2026, providing a possible channel for discussing financing obstacles.^[4] That announcement does not establish an ICBC credit facility or guarantee for this trade.^[4] Before the February 12 investigation deadline, an importer could seek an indicative assessment based on repayment resources available even if deposit cash remained committed for longer.^[2] The practical opportunity is to test a specific order’s financeability, including a case with no assumed refund available for repayment. A useful result would identify the funding gap, repayment source and conditions still to be met, without presuming credit approval or a favourable final determination.