Does acting as a supply agent affect export qualifications?

According to the latest 2025 "Customs Regulations on the Declaration of Import and Export Goods," the core of export declaration lies inOwnership of goods and authenticity of tradeWhen a company procures goods through an agent, special attention must be paid to the following three scenarios:

• The agent holds complete title documents (such as purchase and sales contracts + special VAT invoices) and can normally declare for export.
• The agent only provides intermediary services, and the actual cargo owner is required to handle the export procedures.
• Cross-border supply chain service providers acting as purchasing agents must ensure that the tripartite agreement clearly defines the trading entities.

Three Major Compliance Pitfalls When Exporting Through Agents

The typical cases reported by the General Administration of Customs in 2024 indicate that violations arising from procurement agency are mainly concentrated in:

• Misplacement of trade entities
  • The exporter does not match the operating unit on the customs declaration.
  • The recipient of foreign exchange has no direct connection with the exporter.
• The value added tax chain is broken
  • The agent is unable to provide deductible input invoices.
  • The Risk of Fictitious VAT Invoicing Triggered by Export on Behalf of Others
• Proof of title missing
  • Missing complete logistics documentation chain
  • The agency agreement does not specify the terms of goods delivery.

The Four-Step Verification Method for Compliance Operations

Based on our hands-on experience serving 200+ foreign trade enterprises, we recommend adopting the following verification process:

• Step 1: Confirm the proxy type

  Distinguish between a sales agent (with ownership of goods) and an intermediary agent (only facilitating transactions), and require the submission of the original "Agency Agreement".

• Step 2: Verify the VAT Flow

  Request the agent to issue a special VAT invoice and verify the authenticity of the invoice through the electronic tax bureau.

• Step 3: Establish a trade closed loop

  Ensure the procurement contracts, payment vouchers, logistics documents,Customs documentsThe information is completely consistent among the four.

• Step 4: Retain Evidence for Future Reference

  Preserve complete communication evidence such as email correspondence, WeChat records, etc., for at least 5 years.

Suggestions for Handling Special Scenarios

Provide solutions for common challenging issues:

• Scenario 1: The agent has no import and export rights.

  It is recommended to adopt the "dual-header customs declaration" model, with the operating unit filled in as the actual exporter and the declaring unit filled in as the agency company.

• Scenario 2: Multi-level Agent Procurement

  It is mandatory to obtain the factory certificate from the final manufacturer and establish a complete chain of title transfer documents.

• Scenario 3: Cross-border E-commerce Procurement

  According to the 2025 cross-border e-commerce new policy, it is required to register the agency relationship in the Customs Single Window.

Authoritative Q&A: Latest Customs Supervision Trends

The latest response from the General Administration of Customs 12360 hotline in 2025 indicates:

• Permit legalAgency export,, but strictly investigate "fake self-operation, real agency" practices.
• Implement "three-document matching" (contract, invoice, and logistics document) for agent-procured goods.
• Promote the use of blockchain technology to verify trade authenticity

(Note: This document does not constitute legal advice. For specific business matters, please consult the competent customs authority or professional institutions.)