Can a manufacturing enterprise act as an export agent after all?

According to the "Administrative Measures for the Declaration of Import and Export Goods by Customs" newly implemented in 2025, manufacturing enterprisesExport by proxy is permitted under specific conditions. Since the implementation of General Administration of Customs Announcement No. 68 of 2023, the export agency qualification for manufacturing enterprises has been gradually relaxed, provided the following conditions are simultaneously met:

• 企業(yè)の経営範囲に「貨物輸出入」または「代理輸出入」が含まれている
• Export tax refund (exemption) filing registration has been completed
• Possesses independent legal-person status and has completed the foreign trade operator filing.
• Sign a valid agency agreement with the principal

What essential qualifications are required for export agency services?

Manufacturers engaging in export agency business must establish a comprehensive compliance system:

• Basic Qualifications:
  • Registration of Customs Consignees and Consignors of Import and Export Goods
  • E-port IC card and customs declaration authority
  • SAFE Registry Registration
• Specialized Qualification:
  • Customs Brokerage Authorization Letter (must be filed on the Single Window platform)
  • Advance Classification Ruling for Export Commodities (Applicable to Specific Goods)
  • Certificate of Origin Issuance Eligibility (when involving FTA preferences)

Detailed Explanation of the Export Agency Operation Process

A standardized agency export process comprises eight core stages:

• Sign a written agency agreement (with clearly defined responsibilities)
• Handle inspection and quarantine for export commodities (inspection-involved goods)
• Prepare commercial invoice and packing list
• Declare the export customs declaration (HS code must be accurate to 8 digits)
• Arrange國際物流輸送
• Handle foreign exchange receipts and settlements
• Handle輸出稅還付(All documents required to be collected)
• Complete the follow-up customs verification (retain documents for 5 years)

Self-operated Export vs. Agency Export: How to Choose?

Differences Between the Two Models from the Perspective of 2025 Foreign Trade Practice:

• Cost Comparison:
  • Self-operated exports require a dedicated professional team (annual cost approximately 300,000–500,000 RMB)
  • Agency export service fee (1%–3% of the cargo value)
• Risk Comparison:
  • Self-operated exports bear the full-process risk
  • Agency exports can shift part of the compliance risk.
• Efficiency Comparison:
  • For monthly exports of fewer than 20 orders, the agency model is recommended
  • If annual export volume exceeds USD 5 million, self-operation may be considered.

Three Major Legal Risks That Must Be Noted

According to the 2024 foreign-related civil and commercial model cases released by the Supreme People’s Court, manufacturing enterprises acting as export agents must pay special attention to:

• Joint and Several Liability for Principal’s Fraudulent Qualifications (Shanghai Maritime Court Case No. 72 Min Chu 123, 2024)
• Administrative Penalties for Incorrect Commodity Classification (2025 New Customs Administrative Penalty Regulations)
• Account Freeze Triggered by Abnormal Foreign Exchange Receipts and Payments (as Required by the PBOC’s New Anti-Money-Laundering Rules)

Key Points of the Latest Policy Changes in 2025

Key policy adjustments to watch this year include:

• The filing deadline for electronic agency agreements has been shortened to 3 working days.
• 輸出稅還付「ペーパーレス化」の対象範囲がすべての生産型企業(yè)に拡大
• 稅関AEO認定の加點項目に「代理業(yè)務管理」モジュールが新たに追加
• The State Administration of Foreign Exchange cancels the advance-filing requirement for export proceeds under agency arrangements