Export agentWhat legal liabilities does the system ultimately bear?

Under the framework of the latest 2025 "Customs Law,"Export agentThe party acting as the declarant shall bear:

• Obligation to verify the authenticity of documents: Assume 100% verification responsibility for 7 types of trade documents including commercial invoices and packing lists.
• Foreign exchange verification joint liability: According to the provisions of Document No. 12 issued by the central bank in 2024, agency foreign exchange collection must be filed through the bank's trade foreign exchange receipt and payment system.
• Export tax refundRegulatory responsibility：The agent shall establish a completeExport tax refundDocument retention system, with a retention period of no less than 6 years.

Self-operated export andAgency export,What is the core difference?

• Differences in legal entities:
  • Self-operated export: The production enterprise directly acts as the exporter for declaration.
  • Agency export: The agency company acts as the declarant and bearsCustoms declarationResponsibility
• Cash flow management:
  • Self-operated model: The enterprise directly handles foreign exchange receipts and payments.
  • Agency Model: Foreign exchange transactions must be settled through an agency account, and an additional 0.05% foreign exchange regulatory deposit will be required starting from 2025.

What are the core modules included in professional export agency services?

According to the ISO foreign trade service certification standards, a complete agency service should include:

• End-to-end document management: Professional Production from Proforma Invoice to Certificate of Origin
• intelligent customs clearance system: Direct ERP data connection to the Customs Single Window
• Tax planning services: Including export tax rebate pre-audit and cross-border tax structure design
• Logistics monitoring system: Integrated intelligent inventory management system for AEO-certified warehouses

What are the new changes in the composition of export agency fees in 2025?

• Basic Service Costs: Charged at 0.8%-1.2% of the cargo value (an increase of 0.2% compared to 2024).
• Additional compliance costs:
  • EU Carbon Border Adjustment Mechanism (CBAM) Data Declaration Fee: €50 per declaration.
  • UFLPA Act Compliance Review Fee in the United States: $200-500 per instance
• Exchange rate hedging services: The optional foreign exchange hedging service fee is 0.15% of the contract amount.

How to evaluate the compliance capability of an export agent?

It is recommended to establish an evaluation system from three dimensions:

• Certification of Qualification:
  • AEO Advanced Certified Enterprise (Mandatory under the General Administration of Customs 2025 New Regulations)
  • The proportion of certified international trade compliance professionals (CTP) holders shall be no less than 30%.
• Technical capacity:
  • Possess a declaration system directly connected to the Single Window.
  • RCEP Rules of Origin Intelligent Determination System
• Risk control:
  • Export credit insurance coverage rate ≥80%
  • Establish a comprehensive trade compliance audit system.

How to Prevent Legal Risks Under the Export Agency System?

• Essential elements of contract terms:
  • Clearly stipulate the division of responsibilities for HS code declaration.
  • Agreed mechanism for intellectual property infringement compensation
• Document management standards:
  • The original bill of lading must be controlled by the actual cargo owner.
  • Establish an electronic document dual backup system
• Regular compliance audits:
  • Quarterly Special Verification for Export Tax Refunds
  • Annual Trade Security Compliance Assessment