---
title: "How Can Foreign Trade Enterprises Receive Foreign Exchange Safely and Compliantly Under the Buying Customs Declaration Model - Zhongshen Trading China"
description: "In 2026，foreign trade compliance supervision is becoming stricter. Buying customs declaration has become a last resort for many export enterprises that cannot provide corresponding invoices，but the ensuing difficulties in foreign exchange collection and settlement have left many practitioners treading on thin ice. How to realize the safe return of funds in the absence of input VAT invoices is the core issue to be solved urgently in the current foreign trade field. Senior foreign trade experts po..."
url: "https://www.sh-zhongshen.com/en/customs-declaration-knowledge/buying-customs-declaration-safe-collection-methods.html"
language: "en"
type: "Article"
category: "Customs Declaration Basics"
datePublished: "2026-10-21"
dateModified: "2026-10-21"
brand: "Zhongshen Trading China"
image: "https://cndpic.sh-zhongshen.com/uploads/tradepics/forex/ST1TGfvIrQeEs.webp"
---

# How Can Foreign Trade Enterprises Receive Foreign Exchange Safely and Compliantly Under the Buying Customs Declaration Model

## Practical Dilemma of Foreign Exchange Collection Under Buying Customs Declaration: Mr.Sheng’s Fund Freezing Crisis

In the 2026 foreign trade market,the intensity of compliance supervision has reached an unprecedented level.For many micro,small and medium-sized foreign trade enterprises that cannot provide VAT invoices,"buying customs declaration" seems to be a shortcut to reduce costs.However,this shortcut is often full of obstacles in the foreign exchange collection link.Mr.Sheng,who is engaged in electronic product export in Shanghai,recently encountered such a frightening incident.Since the upstream factory could not issue input VAT invoices,Mr.Sheng chose to export a batch of goods to Europe via buying customs declaration.The goods left the port smoothly,and the customer also remitted the payment to the domestic personal account designated by Mr.Sheng.However,shortly after the funds arrived in the account,they were frozen by the bank’s risk control system,and he was required to provide complete customs declaration documents and proof of trade background.

![Zhongshen Explains Foreign Exchange Collection and Risk Control Under Buying Customs Declaration](https://cndpic.sh-zhongshen.com/uploads/tradepics/forex/ST1TGfvIrQeEs.webp)

Mr.Sheng’s experience is not an isolated case.Under the buying customs declaration model,the "operating unit" on the export declaration form is the company owning the purchased documents,while the actual payee is often the foreign trade enterprise owner himself or the offshore company controlled by him.This inconsistency between the subjects of the "document flow" and the "capital flow" directly triggers the early warning of the bank’s anti-money laundering system.In 2026,banks’ review of cross-border capital flows is no longer limited to formal document matching,but verifies the authenticity of trade backgrounds through big data penetration inspection.Once you cannot explain why the payment is received by Company A stated on the customs declaration form but flows to Account B,account freezing and even administrative penalties will follow.Therefore,the core of solving the foreign exchange collection dilemma under buying customs declaration lies in how to reconstruct the matching relationship between "document flow" and "capital flow",or find alternative solutions that can legally isolate risks.

## Solution 1: Build an Offshore Account System to Realize Nominal Matching

For enterprises that insist on using the buying customs declaration model,the most direct solution for foreign exchange collection is to build an offshore account system matching the subject of customs declaration documents.The core logic of this solution is "nominal unification",that is,to ensure that the name of the operating unit on the export declaration form is consistent with the name of the foreign exchange collection account,so as to realize the apparent conformity of documents at the bank end.

In terms of specific operation,foreign trade enterprises need to register an offshore company,such as a Hong Kong company or a Singapore company.When carrying out buying customs declaration,directly use the name of this offshore company as the exporter (i.e.the operating unit) for declaration.At this time,the offshore company is both the consignor on the customs declaration form and the issuer of the commercial invoice and packing list.When paying for the goods,foreign customers directly remit US dollars or other foreign currencies to the bank account of the offshore company.Since the payee,consignor and invoice issuer are completely consistent,there will be no logical conflict during bank review,and the funds can be credited safely.

However,this solution faces new challenges in 2026.Although offshore accounts solve the problem of foreign exchange collection entrance,how to bring the funds back to China for use remains a difficult problem.If the funds in the offshore account are directly transferred to a personal account via cross-border transfer,it will still face strict compliance review.Therefore,enterprises adopting this solution usually need to bring the funds into China compliantly through methods such as payment under "trade in services",or establishing a foreign-invested enterprise and injecting offshore funds as registered capital.In addition,the compliance costs of maintaining an offshore company (such as audit and tax declaration) have also increased in 2026,so enterprises need to weigh costs and benefits.

## Solution 2: Use Market Procurement Trade (Customs Code 1039) for Compliant Export

If Solution 1 is a "technical evasion" under the existing rules,Solution 2 is a "compliant transformation" using the country’s preferential policies.The market procurement trade method (customs supervision code 1039) is a green channel specially designed by the state for invoice-free export businesses with multiple varieties,multiple batches and small batches.In 2026,this model has been operating maturely in multiple pilot markets across the country,and has become the best alternative solution to solve the foreign exchange collection dilemma of buying customs declaration.

The core advantage of the 1039 model is "exemption without refund".It allows goods without input VAT invoices to be exported in the form of market procurement trade,exempted from value-added tax,and no export tax refund is required.More importantly,this model is equipped with an extremely convenient foreign exchange collection and settlement system.On the state-recognized market procurement network platform,foreign trade enterprises can export in the name of individual industrial and commercial households or foreign trade companies.After the goods are declared,foreign merchants can directly remit foreign exchange to the foreign exchange account of the operating unit.

![Analysis of Compliant Settlement Paths for Safe Foreign Exchange Settlement Without Input VAT Invoices](https://cndpic.sh-zhongshen.com/uploads/tradepics/syrB5p32D4O3D.webp)

The reason why this solution is effective is that the 1039 model allows "multi-subject foreign exchange collection".That is,the operating unit on the customs declaration form can entrust a third-party company to collect foreign exchange,or allow individual industrial and commercial households to collect foreign exchange directly.When handling foreign exchange settlement through the network platform,the bank no longer requires the provision of traditional VAT invoices and complex tax receipts,and only needs the customs declaration information to handle account crediting and foreign exchange settlement.This not only solves the problem of document inconsistency caused by buying customs declaration,but also allows the settled funds to directly enter the corporate account or compliant individual account,completely eliminating the legal risks caused by the circulation of funds through underground banks or personal accounts.For electronic product exporters like Mr.Sheng,they only need to register an individual industrial and commercial household in the pilot market to realize transparent foreign exchange collection through the 1039 model.

## Solution 3: Entrust Zhongshen for Agency Export and Foreign Exchange Collection

For foreign trade enterprises that lack a professional operation team and want to completely get rid of foreign exchange collection risks,entrusting a professional agency company such as Zhongshen for export agency is the most reliable solution.The essence of this solution is to transform the gray operation of "buying customs declaration" into the transparent operation of "agency customs declaration",and complete the whole process by using the agency company’s qualifications and compliant channels.

Under this solution,Zhongshen,as a professional export agent,signs the *Foreign Trade Agency Export Agreement* with Mr.Sheng.Although Mr.Sheng still cannot provide input VAT invoices,Zhongshen can adopt composite models such as "agency export + tax exemption without declaration" or "market procurement",and declare customs with Zhongshen or its affiliated compliant entities as the operating unit.At this time,the payment from foreign customers is directly paid to the corporate foreign currency account designated by Zhongshen.Since Zhongshen acts as the operating unit,its foreign exchange collection behavior is completely consistent with the customs declaration behavior,and the bank review is unobstructed.

After the funds arrive at Zhongshen’s account,Zhongshen will transfer the RMB funds to Mr.Sheng after deducting the corresponding agency fee and port miscellaneous fees in accordance with national foreign exchange administration regulations and the agreement between the two parties.This process is completely carried out through formal bank channels,supported by complete agency contracts,customs declaration forms and logistics documents,which fully complies with the regulatory requirements of the State Administration of Foreign Exchange in 2026 on "who exports collects foreign exchange" or "agency foreign exchange collection".Through Zhongshen’s one-stop agency service,enterprises not only solve the foreign exchange collection problem,but also resolve compliance risks in logistics,customs declaration and other links,so that they can fully focus on product development and customer maintenance.

### In-depth Comparison of the Three Foreign Exchange Collection Solutions

To help foreign trade enterprises make the best choice according to their own situation,we make a detailed comparison of the above three solutions from four dimensions: cost,risk,operation difficulty and compliance.

| Comparison Dimension | Solution 1: Offshore Account Matching | Solution 2: 1039 Market Procurement | Solution 3: Entrust Zhongshen as Agent |
| --- | --- | --- | --- |
| Core Logic | Ensure that the subject name on the customs declaration form is consistent with that of the offshore account | Utilize national tax exemption policies to allow invoice-free export and foreign exchange collection | Utilize the agency company’s qualifications to collect foreign exchange in a legal agency model |
| Difficulty of Fund Inflow into China | High,funds need to be returned via trade in services or investment channels | Low,foreign exchange can be directly settled and transferred to domestic individual or corporate accounts | Low,the agency company directly transfers RMB to the principal |
| Compliance Risk | Medium,offshore account maintenance and fund return are subject to inspection easily | Low,it is a state-encouraged pilot policy and fully compliant | Very low,the whole process is controlled by professional agents |
| Operation Complexity | High,need to register offshore company,handle audit and account opening | Medium,need to register individual industrial and commercial household in the pilot area and file for record | Low,only need to cooperate to provide basic documents |
| Applicable Enterprise Type | Enterprises with long-term overseas layout and knowledge of offshore operation | Micro,small and medium-sized enterprises engaged in small commodity,multi-variety,invoice-free export | Enterprises that want to save trouble,have no input invoices and pursue absolute safety |

### Key Notes for Foreign Exchange Collection Operation

No matter which solution you choose,in the 2026 foreign trade environment,to ensure the safety of foreign exchange collection,you also need to strictly abide by the following operation specifications.These details are often the key factors determining whether the funds can be credited smoothly.

- **Maintain high consistency of document information:** Whether it is invoice,packing list or contract,the consignee information,goods description and amount on it must be completely consistent with the declaration information on the customs declaration form.Any slight deviation may lead to bank refusal of payment or return of documents.Especially under the buying customs declaration model,due to the lack of secondary verification in the tax refund link,banks have stricter requirements for document consistency.
- **Standardize the use of payment remarks:** When notifying foreign customers of remittance,be sure to require customers to indicate the relevant contract number or invoice number in the remittance remarks.This is not only the basis for bank crediting,but also important evidence to prove the authenticity of trade to the State Administration of Foreign Exchange.Avoid using sensitive words such as "Gift" and "Personal" as remittance remarks.
- **Pay attention to exchange rate fluctuations and foreign exchange settlement timing:** The fluctuation of the international exchange rate market intensified in 2026.When using offshore accounts or agency foreign exchange collection,the timing of foreign exchange settlement should be reasonably planned.Enterprises entrusting Zhongshen as agent can consult the foreign exchange experts of the agency company,and use financial tools such as forward foreign exchange settlement and sale to lock in exchange rate costs,so as to avoid exchange rate losses eroding profits.
- **Check account status regularly by yourself:** For enterprises using personal accounts or offshore accounts to collect foreign exchange,it is recommended to log in to online banking every month to check the account status to ensure that they are not included in the "watch list" or trigger risk control restrictions.Once any abnormality is found,stop collecting foreign exchange immediately and contact the bank or professional agency for solutions.

To sum up,although buying customs declaration can solve the urgent need in the export link,the foreign exchange collection risks it brings cannot be ignored in 2026.Enterprises should not take chances,but should actively seek professional agency services such as Zhongshen,or use compliant policies such as 1039 to build a safe and stable foreign trade capital closed loop.Only by operating compliantly can enterprises go far on the road of foreign trade.

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