What isAgency export,No Foreign Exchange Settlement?

Agency export without foreign exchange settlement refers to a special trade mode in which a foreign trade agent handles export procedures on behalf of others, but the payment for goods is not settled through domestic banks. According to Article 38 of the latest Regulations on the Administration of Foreign Exchange in 2025, such businesses need to meet three core conditions: The actual ownership of the goods has been transferred to the overseas buyer. The entire process of capital flow can be traced and verified. The enterprise needs to complete the filing in the special customs supervision area.

• The 2025 operation process needs to follow the double - filing + electronic verification mechanism:
• Full traceability verification of fund flows
• Enterprises must complete customs special supervision zone registration

How to Conduct a Compliant Operation of Agency Export without Foreign Exchange Settlement?

2025 procedures must follow 'dual filing + electronic verification' mechanism:

• Step 1: Filing in the Special Customs Supervision Zone
  • Submit the Record-filing Form for Enterprises in the Bonded Logistics Center to the local customs
  • Provide overseas collection account information and a description of the purpose of funds
• Step 2: Electronic declaration to the State Administration of Foreign Exchange
  • Submit the Special Trade Declaration Form through the Digital Service Platform of the State Administration of Foreign Exchange
  • Upload international trade contracts and transportation documents simultaneously

What Risks Exist in Agency Export without Foreign Exchange Settlement?

According to the foreign trade compliance audit cases in 2025, the main risk points include:

• Tax inspection risk: Prepare complete zero - VAT rate certification materials
• Foreign exchange supervision risks: Ensure that a single transaction does not exceed the limit of $500,000
• Legal dispute risks: It is recommended to adopt the standard contract terms of the ICC (International Chamber of Commerce)

How to Deal with the Dilemma of Capital Repatriation?

The latest solutions in 2025 include:

• Use Hong Kong/Singapore offshore companies for fund pool management
• Achieve sub - account settlement through third - party payment institutions (such as Payoneer)
• Apply for the qualification of a pilot enterprise for cross - border RMB settlement

What are the Key Changes in the 2025 Policy?

• Mandatory connection between electronic customs declaration forms and the foreign exchange verification system data
• The document retention period is extended to 7 years (originally 5 years)
• New blockchain traceability verification requirements are added

What are the Common Operation Misunderstandings?

• Misconception 1:'No forex settlement = complete tax avoidance' (still requires tax-exempt declaration)
• Misconception 2:'No formal contract needed' (must sign tripartite agreement)
• Misconception 3:'Unlimited forex receipt delay' (maximum 360 days)

Specific recommendations :Effective April 2025, Cross-border Trade Forex Management Rules require all agency exports to complete filing via 'International Trade Single Window'. Enterprises should conduct forex compliance risk assessments in advance, seeking professional trade service support when needed.