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A Comprehensive Analysis of Agency Export Qualifications: How to Ensure Legal and Compliant Operations?

What qualifications are required for entrusting agency export

I.Agency export,What Legal Business Qualifications Does the Company Need?

According to the Customs Law of the Peoples Republic of China and the Foreign Trade Law, enterprises that legally carry out agency export business must possess the following qualifications simultaneously:

  • Foreign Trade Operator Registration Record: Complete the filing in the Ministry of Commerce system and obtain the right to import and export
  • Registration of Customs Declaration Entities: Includes dual qualifications of import and export consignors/consignees and customs declaration enterprises
  • Register of Foreign Exchange Administration: Has the qualifications for foreign exchange receipt and payment and declaration
  • Electronic Port IC Card: Used for the transmission of customs declarations and payment of taxes and fees
  • Determination of Export Tax Rebate (Exemption) Qualification: Tax rebate qualification certificate issued by the tax authorities

33. II. How to Verify the True Qualifications of an Agency Company?

It is recommended to conduct triple verification through official channels:

  • Query on the official website of the General Administration of Customs:
    • Please log in to "Internet + Customs" (online.customs.gov.cn).
    • Enter the company name/code in the "Company Information Query" module.
  • Verification in the system of the State Administration of Foreign Exchange:
    • Request the agent to provide a screenshot of the List of Enterprises for Trade Foreign Exchange Receipt and Payment,
    • Verify the foreign exchange receipt ability through the banks cross - border payment and receipt system
  • Confirmation by the tax department:
    • Inspect the original Export Tax Rebate (Exemption) Filing Form,
    • Check the qualification documents stamped by the tax authorities

III. Additional Requirements for the Agency Export of Special Commodities

When specific regulated goods are involved, the agency company also needs to obtain special permits:

  • Medical Devices: Medical Device Business License (Class II/III)
  • Chemical products: Hazardous Chemicals Business License
  • 28. Food category: Entry - Exit Inspection and Quarantine Filing + Export Food Production Enterprise Filing
  • Technology export: Registration Certificate of Technology Import and Export Contract

IV. Typical Risk Cases of Entrusted Agency Export

Irregular cases investigated and dealt with in a certain place in 2024 show:

  • A trading company used an expired customs code to act as an agent for export, resulting in the entire container of goods being detained at the port
  • An agency enterprise failed to handle the export tax rebate (exemption) filing in a timely manner, causing the principal to lose the tax rebate
  • A service provider operated foreign exchange receipt and payment in violation of regulations, triggering an administrative penalty of 5 million yuan from the State Administration of Foreign Exchange

V. 5 Golden Criteria for Selecting an Agency Service Provider

According to the operating specifications recommended by the World Customs Organization (WCO):

  • Conduct on - site inspections of the business premises: Check the consistency between the office space and the registered address
  • Check the tax refund records of the past three years: Require the tax refund details issued by the tax bureau
  • Test the connection of the customs clearance system: Confirm that its customs declaration system is in real - time communication with customs data
  • Review cooperation cases: Require those from customers in the same industryExport customs clearanceDocument (Desensitized Version)
  • Verify the ability of fund supervision: Confirm whether its foreign exchange account is included in the bank supervision system

VI. In - depth Analysis of Common Questions

Q: Can individual industrial and commercial households entrust an agent for export?
A: According to the latest policy in 2025, individual industrial and commercial households need to complete the record - filing of foreign trade operators, and the annual export volume must exceed 1 million yuan before they can entrust an agent.

Q: What legal documents need to be signed for agency export?
A: Three core agreements must be included: ① Agency Export Agreement ② Authorization Letter for Foreign Exchange Receipt and Payment ③Export tax refundEquity Transfer Agreement.

Q: What special regulations apply to cross - border e - commerce?
A: According to Announcement No. 12 of the General Administration of Customs in 2025, for cross - border e - commerce agency export, the following additional procedures need to be handled: ① Record - filing of cross - border e - commerce enterprises ② Connection of the import and export commodity traceability system ③ Record - filing of cross - border payment channels.

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