Is export agency reflow legal?

According to the General Administration of Customs Announcement No. 38 of 2025 and the latest SAFE policies, export agency reflow itself is not illegal, but must meet three conditions:① Genuine trade background ② Complete documentation chain ③ Compliance with foreign exchange verification requirements. Special attention should be paid to the new 2025cross-border e-commerce data network reportingrequirement, where all reflow goods must complete electronic filing through the Customs Single Window.

How to avoid capital reflow being classified as forex evasion?

After the implementation of 2025 foreign exchange management new policies, the following compliance paths are recommended:

• Normal trade settlement path
  • Overseas payment → Foreign exchange account of agency company → Supported bycustoms clearanceDocument settlement
  • Agency service fee payment requires separate declaration
• Filing path for special circumstances
  • Single transactions exceeding $500,000 require 15-day advance filing
  • Related-party transactions require price reasonability proof

What is the correct declaration process for goods return reflow?

After the General Administration of Customs implemented theThree-document matching system 2.0, Return operations must strictly follow:

• Prepare original export customs declaration form and tax refund copy
• Quality issue certificate issued by overseas buyer (requires embassy authentication)
• Complete return application filing 72 hours before goods arrive at port

Special reminder: Starting from 2025 for returned goodsExempt from import tariffsBut requires repayment of tax refunds already received. Specific calculation formula: Repayment amount = (Tax refund ÷ Total export value) × Returned goods value.

AgentlyExport tax refundHow to avoid repayment demands?

According to State Taxation Administration Document No. 15 of 2025, special attention is required:

• Agency agreement must clearly specify tax refund principal rights and obligations
• Foreign exchange receipt period shortened towithin 180 days
• Added newIntelligent risk control indicators: Continuous 3-month collection rate below 85% will trigger warning

Which circumstances may trigger special audits for reflow transactions?

2025 customs audit priorities include:

• High-frequency small-amount returns(Quarterly exceeding 5 times with single transaction below $10,000)
• Abnormal Value Fluctuation(Same category goods price deviation exceeding market price by 30% or more)
• Abnormal logistics tracking(If the overseas stay is less than 15 days)

What risks should be considered when selecting agency service providers?

It is recommended to focus on verifying the following qualifications:

• Whether possessingCustoms AEO Advanced Certification
• Is the foreign exchange income and expenditure enterprise classificationCategory A
• Is it connected toThe International Trade Single Window 3.0 system
• Historical violation record query (can be verified through the Enterprise Credit Information Publicity System)