Can production companies represent exports?

According to the Customs Import and Export Goods Declaration Management Measures implemented by 2025Agents are allowed to export under certain conditionsSince the implementation of Announcement No. 68 of the General Administration of Customs in 2023, the qualifications for manufacturing enterprises to act as export agents have been gradually relaxed, but the following conditions must be met simultaneously:

• The business scope of the enterprise includes "import and export of goods" or "import and export agency."
• Export (exempt) tax registration has been processed
• Have the status of independent legal persons and register of foreign trade operators
• Signing effective agency agreements with the client

What qualifications are required for export agency?

Production enterprises to carry out the agency export business need to build a complete compliance system:

• The basic qualifications:
  • Registration of customs registration of import and export goods
  • Electronic port IC card and customs reporting authority
  • Register of Foreign Exchange Administration
• The Special Qualifications:
  • Agent Customs Offering (required in a single window)
  • Pre-determined classification of export goods (applicable to specific goods)
  • Qualification for issuing certificates of origin (in the case of preferential free trade agreements)

Export Operating Process Details

The standardized agent export process contains eight core links:

• Sign a written agency agreement (clear division of responsibilities is required)
• Export Goods Inspection and Inspection (Inspection of Goods)
• Commercial invoices and packaging.
• Declaration of export customs declaration (HS code must be accurate to 8 bit)
• arrangedInternational logisticsTransportation is
• Treatment of Foreign Exchange Settlements
• HandledExport tax refund(A certificate is required)
• Complete customs follow-up verification (retain documents for 5 years)

How to choose self-export vs. agency export?

The differences between the two models are seen from the perspective of foreign trade practice in 2025:

• Comparison of costs:
  • Self-operated export requires a professional team (annual cost approximately 300,000-500,000 RMB)
  • Proxy export payment service fee (value of goods1%-3%)
• Comparison of risks:
  • Self-exporting carries all process risks
  • Agent exports can transfer part of compliance risk
• Comparison of efficiency:
  • Monthly export20 The following recommended agent model
  • Annual exports over500$1 million can be considered self-employed

Three legal risks to consider

According to the typical cases of foreign-related civil and commercial affairs released by the Supreme Peoples Court in 2024, production enterprises acting as export agents need to pay special attention to:

• Principals Qualification Fraud Joint Liability (Case No. 123, First Instance, Min 72, Shanghai, 2024)
• Administrative Penalties Caused by Error in Classification of Goods (New Regulation on Customs Administrative Penalties)
• Freezing of accounts caused by abnormal foreign exchange receipts (central bank new anti-money laundering requirements)

Key Points of Policy Changes for 2025

Policy adjustments worth considering this year include:

• Registration time reduced to 3 working days
• Export tax refundThe scope of "paperless" operations has been expanded to cover all manufacturing enterprises.
• The "Agency Business Management" module has been added as a bonus item for Customs AEO certification.
• The Foreign Exchange Administration cancelled the requirement for pre-registration of agent export collection