Agentlycustoms clearanceTo which party does the export value actually belong?

According to the Regulations on the Administration of Declaration of Import and Export Goods of the Customs (Revised Version of Announcement No. 122 of the General Administration of Customs in 2023),The statistical data on export volume is legally based on the "Domestic Consignor/Consignee" field in the customs declaration form.. The following key points need to be noted in actual operations:

• When using double - header customs declaration (manufacturer + trader), the customs statistics are carried out according to the following priorities:
  • The actual cargo - owner enterprise with import and export rights
  • The unit that receives and pays foreign exchange
  • The signing party of the customs declaration contract
• Under the pure agency customs declaration mode (single - header), 100% of the export value is recorded in the account of the principal
• The newly introduced "Supply Chain Collaborative Declaration" model in 2025 allows affiliated enterprises to share export data.

Will agency customs declaration affectExport tax refundthe declaration?

Agency customs declaration itself does not affectExport tax refundthe rights and interests, but it is necessary to ensurethe principle of consistency of the three - document information:

• The declaration entity of the customs declaration form must be consistent with the issuer of the VAT invoice
• The foreign exchange collection account should correspond to the domestic consignor/consignee of the customs declaration form
• The transport document should reflect the actual party of cargo - right transfer

Typical case: In 2024, an electromechanical enterprise experienced a delay in tax rebate due to the use of an unaffiliated agent. Later, through the supplementation ofthe agency agreement + payment voucher for the goodsthe data traceability was completed.

How to avoid the segmentation of export data caused by agency customs declaration?

In response to theEnterprise Group - based Supervisionpolicy promoted by the General Administration of Customs in 2025, the following measures are recommended:

• Establish an internal customs declaration data collection system within the group
  • Member enterprises use the unified social credit code segment
  • Set up a special declaration channel for related party transactions
• Standardize the terms of the agency agreement
  • Clarify the terms of data declaration authority
  • Agree on the responsibility for keeping original documents

Will cross - border agency customs declaration affect the determination of the exporting country?

According to the WTO rules of origin and the latest interpretations of Chinas customs:

• The location of the customs declaration agentNo changeDetermination of the country of origin of goods
• Handling in special circumstances:
  • For entrepot trade, the information of the middleman needs to be declared
  • For exports from the bonded area, the supervision method needs to be marked separately

Important notice: Starting from January, 2025ASEAN Free Trade AreaThe customs of member states will pilot the sharing of customs declaration data by agents. It is recommended to conduct consistency verification of declarations in advance.

How to verify the accuracy of agency customs declaration data?

It is recommended that enterprises establishrisk control mechanism:Verification mechanism:

• System docking: Obtain customs declaration data in real - time through the single window
• Document comparison: Check the differences between the customs declaration form and the shipping list every month
• Special audit: Hire a third - party institution to trace trade data

A certain garment export enterprise discovered through the aforementioned methods in the fourth quarter of 2024 that7.2% of the declared customs value was under - reported, and completed the statistical correction in a timely manner.