---
title: "Full Process Analysis of Entrusting Customs Broker for Import Agency - Zhongshen Trading China"
description: "In 2026，China's import regulatory environment continues to tighten，and enterprises handling customs declaration independently face three major challenges: complex documentation，upgraded quarantine standards，and stricter price verification. This article focuses on a real import case of New Zealand infant formula，deeply deconstructs the end-to-end service of pre-audit，customs declaration，commodity inspection and distribution accumulated by Zhongshen over 20 years of industry experience，and re..."
url: "https://www.sh-zhongshen.com/en/customs-declaration-knowledge/customs-broker-import-process.html"
language: "en"
type: "Article"
category: "Customs Declaration Basics"
datePublished: "2026-10-04"
dateModified: "2026-10-04"
brand: "Zhongshen Trading China"
image: "https://cndpic.sh-zhongshen.com/uploads/tradepics/tgXatJTXVjwnw.webp"
---

# Full Process Analysis of Entrusting Customs Broker for Import Agency

## Import Background and Operational Difficulties of New Zealand Infant Formula

In the first quarter of 2026,the CIF volume of infant formula imported by China from New Zealand increased by 23% year-on-year,but at the same time,the customs declaration rejection rate and abnormal inspection rate climbed to a record high.Behind this contrast is a gap between the iteration of regulatory rules and the operational capabilities of enterprises.As the world’s largest dairy exporter,New Zealand’s milk powder products entering the Chinese market must meet three regulatory frameworks at the same time: Measures for the Supervision and Administration of Inspection and Quarantine of Imported and Exported Dairy Products,Measures for the Administration of Product Formula Registration of Infant Formula Milk Powder,and Order No.249 of the General Administration of Customs of China.

![Full Process Analysis of Entrusting Customs Broker for Import Agency](https://cndpic.sh-zhongshen.com/uploads/tradepics/tgXatJTXVjwnw.webp)

In actual operation,enterprises often encounter three types of difficulties: First is the documentation chain completeness trap.A Hangzhou e-commerce client once faced port entry refusal because the health certificate issued by the New Zealand manufacturer did not mark the specific source of vitamin D3.Second is HS code classification dispute.The tariff rate of whole milk powder differs from that of modified milk powder by 8 percentage points,and incorrect classification directly leads to the risk of tax supplementary payment.Third is the dynamic requirement of label compliance.In March 2026,the State Administration for Market Regulation of China updated the General Standard for the Labeling of Prepackaged Foods,requiring that imported infant food must clearly mark "This product complies with Chinese national standards" on the Chinese label.Many enterprises have to rectify the entire batch of goods due to information lag.

## Core Positioning of Zhongshen in the Import Chain

Zhongshen does not simply execute customs declaration instructions,but acts as an embedded compliance officer involved in the front end of trade.2025 service data shows that 87% of our pre-audits are launched at the stage when customers sign procurement contracts,and this model advances the risk identification node by an average of 17 working days.Its core role is reflected in three dimensions: Rule interpretation capability,which converts customs AEO certification standards and registration requirements of the State Administration for Market Regulation into an executable operation checklist; Resource integration capability,which establishes direct electronic data connection channels with Yangshan Port and Waigaoqiao Free Trade Zone; Risk hedging capability,which reduces customers’ capital occupation through tariff guarantee insurance and rapid response mechanism for abnormal inspections.

Take the maternal and infant supply chain company run by Mr.Fu as an example.In 2026,the company planned to introduce a brand of goat milk powder from New Zealand.Zhongshen intervened when the brand provided the draft formula,and found that the maximum allowable addition amount of GOS prebiotic used in this product in China is 6.4g/100g,while the local standard in New Zealand is 8g.We promptly required the brand to adjust the formula and resubmit the registration materials,avoiding the subsequent risk of port destruction.

## Four-stage Deconstruction of Import Process and Compliance Key Points

### Stage 1: Document Pre-audit and Registration Access

This stage usually takes 25-35 working days,and determines whether the goods can legally enter China.The New Zealand supplier qualification database established by Zhongshen covers 23 major dairy enterprises,and can verify the validity of their registration numbers in China in real time.Key documents include: Certificate of Origin (needs to specify specific rules of origin clauses),Health Certificate (must be signed by an official veterinarian of the Ministry for Primary Industries (MPI) of New Zealand and stamped with an official seal),Composition Analysis Report (needs to test chlorate,perchlorate and other new monitoring items added in 2026),Formula Registration Certificate (issued by the State Administration for Market Regulation,valid for 5 years).

Zhongshen’s pre-audit system automatically compares the consistency of information on the three certificates.We once found that the production date on the health certificate of a batch of products did not match that on the certificate of origin,and promptly required the New Zealand party to reissue it,avoiding port detention.In addition,for the extended declaration clause of the Administrative Provisions on the Registration of Overseas Production Enterprises of Imported Food added in 2026,the company will remind customers to apply for renewal 90 days in advance.

### Stage 2: Port Customs Declaration and Price Verification

![2026 Guide for Customs Declaration of Imported Infant Formula](https://cndpic.sh-zhongshen.com/uploads/tradepics/ThJPq7Fq3arMT.webp)

3 working days before the goods arrive at the port,Zhongshen submits the declaration to customs.The biggest challenge in this link is the determination of the rationality of the transaction price.In 2026,the customs launched a special price verification for infant formula,referring to the gross margin data in the quarterly financial reports of international dairy enterprises.Zhongshen’s response strategy is: clearly specify special relationship clauses such as intellectual property royalties and resale income return in the procurement contract,and prepare price supporting materials for New Zealand’s exports to the Southeast Asian market in the same period.

Customs declaration form filling must be accurate to the 10-digit HS code.Whole milk powder (0402.2100) and skimmed milk powder (0402.2900) belong to completely different automatic import license management categories.Zhongshen’s customs affairs system has built-in logical verification,which can automatically intercept declarations where the code does not match the product composition description.In April 2026,the "growth milk powder" declared by a client had a fat content of only 1.2% on the ingredient list,the system forced manual review,and finally classified it as skimmed milk powder,saving the client more than 120,000 RMB in tariff expenditure.

### Stage 3: Commodity Inspection Sampling and Laboratory Testing

Infant formula is a high-risk food,and 100% of the shipments are subject to on-site inspection.The on-site coordinators stationed by Zhongshen at Yangshan Port will obtain manifest data before the ship berths,and pre-arrange inspection priority.Compared with 2025,the 2026 test item list added Cronobacter detection,and the test cycle is extended to 15 working days.

Label review is another key point.The full-time label reviewers equipped by Zhongshen will check the consistency between the Chinese label and the registered formula.In particular,the rounding interval of energy,protein,fat and carbohydrates in the nutrition facts table must comply with the provisions of GB 13432-2026.There was once a batch of goods marked "lactoferrin (LF)" instead of "lactoferrin",which was considered inconsistent with the registration certificate.Zhongshen coordinated with the market supervision department to issue an explanation letter,proving that LF is a general industry abbreviation,and the goods were released.

### Stage 4: Warehousing,Distribution and Post-clearance Supervision

After passing commodity inspection,the goods enter the temperature-controlled warehouse of Zhongshen in the free trade zone.The system maintains an environment of 2-6and uploads temperature data to the customs supervision platform every 4 hours.In response to the Imported Food Sales Record Traceability System implemented in 2026,the company assigns a unique code to each can of milk powder,realizing full-link scan code query from the New Zealand pasture to Chinese consumers.

In the post-clearance supervision link,Zhongshen will actively collect customs inspection feedback within 30 days after the goods are released.In May 2026,a batch of products was complained by downstream dealers for solubility problems.The company immediately launched retained sample re-inspection,found that it was caused by temperature fluctuation during transportation,quickly isolated the same batch of inventory and notified the customer to start the recall procedure,avoiding damage to the brand reputation.

## Practical Case: Crisis Resolution of Mr.Fu’s Company for First-time Import

At the beginning of 2026,Mr.Fu’s company obtained the agency right of an organic milk powder brand from New Zealand,with the first batch of 8,000 cans worth 460,000 US dollars.Zhongshen found in the pre-audit stage that the brand’s organic certification was issued by AsureQuality of New Zealand,but the certificate did not mark the record number of China’s organic product certification mark,which did not meet the mutual recognition requirements of the Measures for the Administration of Organic Product Certification.The company urgently contacted the New Zealand exporter,coordinated to add the record information on the certificate,and at the same time submitted a situation description to the General Administration of Customs,applied for release against guarantee,and reduced the originally expected 15-day shipping delay to 3 days.

After the goods arrived at Waigaoqiao Port,the customs considered the declared price too low and required price supporting materials.Zhongshen retrieved the production cost composition report of New Zealand organic milk powder,the futures price trend data of international organic products,and explained the first order discount policy enjoyed by Mr.Fu as a new agent.Finally,the customs accepted the declared price.In the commodity inspection stage,laboratory test showed that the vitamin A content was 98% of the registered formula,which was within the allowable error range,but the marked value on the label was 100%,which was a labeling defect.According to the clause of "Label defects that do not mislead consumers can be rectified" in the Implementation Regulations of the Food Safety Law 2026,Zhongshen applied for affixing corrected labels on site,avoiding the risk of return shipment.

The entire batch of goods took 11 working days from arrival at the port to warehousing,which is 9 days shorter than the industry average cycle,so Mr.Fu caught the golden period of spring stocking for maternal and infant stores.

## Hidden Value of Zhongshen’s Services

The value of a professional customs declaration agency is not only reflected in customs clearance speed.2026 customer return visit data of Zhongshen shows that among enterprises using our agency service,the passing rate of AEO advanced certification in customs credit rating assessment reaches 73%,which is much higher than the industry average of 21%.This benefits from the annual compliance audit service provided by the company,which actively helps enterprises improve their trade document file management system.

In terms of cost control,through three measures: batch declaration,group purchase of tariff guarantee insurance,and rapid disposal of abnormal inspection,Zhongshen saves customers an average of 8-12% of comprehensive costs.More importantly,risk avoidance: in the first half of 2026,the company successfully warned and intercepted 3 major risks involving expired qualification of New Zealand suppliers and 1 major risk involving expired formula registration certificate,with potential losses exceeding 20 million RMB.

## 2026 Import Regulatory Trends and Response Recommendations

Based on the information interaction analysis between Zhongshen and the data center of the General Administration of Customs of China,there will be three policy changes in the second half of 2026: First,infant formula will be included in Class A risk of the Catalog of Risk Classification Management of Imported Food,and the inspection rate will be increased to 30%; Second,blockchain electronic signature will be activated for health certificates of New Zealand dairy products exported to China,and the parallel period of paper certificates will last until the end of 2026; Third,the State Administration for Market Regulation plans to establish a dynamic verification mechanism for formula registration,and implement unannounced inspections on registered products.

In response to these changes,Zhongshen has launched three countermeasures: upgrade the blockchain document verification system to achieve direct data connection with New Zealand MPI; establish a dynamic monitoring database for registered formulas to track regulatory announcements in real time; expand the team of on-site coordinators to ensure response efficiency under high inspection rate.If an enterprise plans to import independently,it needs to evaluate whether it has the technical capability and labor cost to continuously track policy changes.

| Service Module | Zhongshen Operation Standard | Common Deviations of Enterprise Independent Operation | Risk Difference Value |
| --- | --- | --- | --- |
| Document Pre-audit | AI scan of 18 compliance points + manual review | Average 3.2 key elements missed | Declaration rejection rate reduced by 76% |
| HS Code Classification | Database real-time connection with customs classification decisions | Error rate around 15%,leading to tax supplementary payment | Tariff cost saved by 8-12% |
| Commodity Inspection Coordination | On-site specialist + laboratory expedited channel | Average communication delay of 4.5 working days | Release cycle shortened by 40% |
| Post-clearance Traceability | Blockchain coding + active reporting of sales flow | Passive response to regulatory random inspection | AEO certification passing rate + 52% |

The essence of choosing a customs declaration agency is to convert uncertain compliance costs into controllable service fees.What Zhongshen has accumulated over 20 years is not only operation procedures,but also in-depth understanding of regulatory logic and experience in handling abnormal situations.Against the background of refined and digital regulation in 2026,professional agency service has changed from an option to a necessity.

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