I.Agency export,Who is actually responsible for foreign exchange settlement?

According to the latest Implementation Rules for the Administration of Foreign Exchange in Cross - border Trade in 2025, under the agency export mode, there areDivision of dual - subject responsibilities:

• The domestic consignor (agent) recorded on the customs declaration form shall bear the obligation of foreign exchange declaration
• The actual owner of the goods (the principal) reserves the right to claim foreign exchange earnings

In practical operations, the agency company needs to go throughThe cross - border collection and payment centralized processing systemComplete foreign exchange verification and write - off, and at the same time provide the principal with a foreign exchange collection split slip as a settlement voucher.

II. Can foreign customers directly remit foreign exchange to the factory in agency exports?

This operation has major compliance risks:

• The State Administration of Foreign Exchange requiresThe capital flow to be consistent with the goods flow, and the payer needs to match the overseas consignee on the customs declaration form
• If the factory directly receives foreign exchange, it needs to meet the following conditions simultaneously:
  • The agency agreement clearly stipulates the foreign exchange collection method
  • Provide a tri - party settlement agreement for filing
  • CompleteExport tax refundSubject identification

In 2025, the State Administration of Foreign Exchange has strengthened the monitoring of abnormal cross - border capital flows. It is recommended to adoptBank regulatory accountCarry out fund transfer.

III. What documents are needed for foreign exchange payment in agency exports?

The core document list includes:

• Original export customs declaration form (signed and sealed by the reporting unit)
• Agency export agreement (foreign exchange settlement terms need to be clearly defined)
• Proforma invoice and commercial contract (the amount and currency are consistent)
• For cross - border RMB settlement, it is necessary to supplementRCPMIS systemDeclaration voucher

Special reminder: In 2025, the General Administration of Customs will promote the verification of electronic customs declarations. It is recommended to make preparations simultaneouslyDigital signature certification document.

How to complete domestic settlement after the foreign exchange arrives?

Two compliant paths are recommended:

• Agency foreign exchange receipt model:
  • The agency company shall settle the foreign exchange within 5 working days after receiving it
  • Settle RMB with the principal based on the bank receipt
• Entrusted foreign exchange purchase mode:
  • The principal provides a certificate of foreign exchange purchase quota
  • The agency company locks the exchange rate through foreign exchange derivatives

Note: In 2025, additional submissions are required for foreign exchange derivative transactionsLetter of commitment for a genuine trade background.

What new risks need to be guarded against in agency export foreign exchange payment?

In 2025, special attention should be paid to three types of risks:

• Sanctions compliance risk: The US OFAC is accelerating the frequency of updating the Entity List
• Digital currency payment risk: Cross - border digital RMB payments require the completion of anti - money laundering certification
• Exchange Rate Fluctuation Risk: It is recommended to use a combination of foreign exchange option tools for hedging

It is recommended to conduct monthly inspectionsGlobal sanctions list database, Establish a payer whitelist system.

How to handle special foreign exchange payment scenarios for agency exports?

Processing suggestions for common special scenarios:

• Make foreign exchange payments in batches:
  • For multiple foreign exchange payments corresponding to a single customs declaration, a logistics segmentation certificate needs to be provided
  • The cumulative amount error shall not exceed ±3% of the customs declaration amount
• Foreign exchange payment from a third - party country:
  • Documents proving entrepot trade need to be supplemented
  • Provide an explanation of the capital flow path

Starting from 2025, for deferred foreign exchange collection exceeding 90 days, it is necessary to report to the State Administration of Foreign Exchange within 15 days after the export of goods.