I. Does an agency export necessarily require a written agreement?

According to the latest version of the Foreign Trade Law in 2025,foreign tradea written agency agreement must be signed for agency export. The following core clauses should be clearly stipulated in the agreement:Division of rights and obligations of both parties (especially the ownership of goods)

• The entity responsible for customs declaration and the way of liability assumption
• The process of foreign exchange receipt and payment and tax rebate handling
• Dispute resolution mechanism
• A case of a tax rebate dispute caused by an oral agreement of a certain electromechanical enterprise in 2024 shows that when there is a lack of a written agreement, the tax authorities may identify the actual owner of the goods as the declaration entity.

It needs to be issued in the double - header mode:

II. How to issue a VAT invoice for an agency export?

Seller column: The actual production/supplying enterprise

• Buyer column: The name of the agency company
• The remarks column must indicate:
• The words agency export,
  • The name of the actual overseas buyer
  • The export contract number
  • After the implementation of the new regulations on electronic invoices in 2025, a scanned copy of the agency agreement needs to be uploaded as an attachment for invoicing.

III. The agency company can handle

The entity responsible for tax rebate declaration can only be the actual export enterprise (the principal), but the agency company should provide:Export DrawbackAccording to Document No. 38 of the State Administration of Foreign Exchange in 2025,

A copy of the customs declaration form stamped with the official seal

• Certificate of agency export of goods
• Foreign ExchangeA complete export agency agreement should be attached with:Voucher
• From 2025, the agency company needs to transfer the full set of documents to the principal within 15 working days after the goods leave the country.

Special reminder:Basic documents:

IV. What declaration materials are needed for agency export?

• Agency export agreement (original)
  • Customs declaration documents:
  • Power of Attorney for Application of (CO)
  • Packing list
• Power of attorney for customs declaration
  • Foreign exchange receipt vouchers:
  • Commercial Invoice
  • transportation documents
• Declaration form of the State Administration of Foreign Exchange
  • Bank foreign exchange receipt slip
  • Special attention should be paid to cross - regional agency:

V. What are the risk points of agency export in different locations?

Consistency between the place of export tax rebate filing and the actual source of goods

• Matching of logistics tracks and customs declaration information
• Procedures for the transfer of goods in special supervision areas
• In 2025, the National Integrated Customs Clearance Supervision System newly launched by the General Administration of Customs requires that cross - regional agency businesses must be electronically filed in advance.

Control of key time nodes:

VI. How to avoid the risk of the declaration time limit for agency export?

Within 10 days after the goods leave the country: Complete the electronic data transmission of the customs declaration form

• Within 30 days after receiving foreign exchange: Complete the declaration in the foreign exchange monitoring system
• Before the end of the VAT tax return period in April of the following year: Complete the tax rebate declaration
• It is recommended to establish a time - limit tracking table for agency business and set up a 15 - day early warning mechanism.

Processing procedures according to different situations:

VII. What should be done if there is a declaration error in agency export?

If an error is found before customs declaration:

• Immediately submit an application for form modification to the customs
  • Simultaneously notify the principal to suspend subsequent operations
  • Within three months after customs declaration:
• Prepare an explanation of the situation and supporting materials
  • Apply for customs declaration form modification through the single window
  • Apply for customs declaration form modification through a single window
• Involving errors in tax refund declaration:
  • The original declaration records must be invalidated.
  • Resubmit the correct declaration data.

In 2025, the new customs regulations allow non - deliberately - intended errors to be exempted from administrative penalties within a time limit, but the relevant taxes need to be paid up.