2026 Interpretation of Proxy Import Goods Regulations and Enterprise Practical Operation Guide

Interpretation of Core Points of 2026 Proxy Import Goods Regulations

Since 2026,the General Administration of Customs and the Ministry of Commerce have updated a batch of regulations related to proxy import of goods,with core adjustments centered on two directions: "facilitated declaration + precise supervision".Many enterprises have found in practice that the new regulations not only bring opportunities for improved customs clearance efficiency,but also put forward new requirements for compliance management.The following is a plain interpretation of 3 key points:

• Point 1: Full implementation of "two-step declaration": When importing goods,enterprises can first submit a "summary declaration" (including basic information such as goods name,quantity,origin,etc.) to apply for customs clearance,and supplement the "full declaration" (including detailed materials such as commodity code,price certificate,etc.) within 10 working days after the goods are released.Previously,all materials were required to be submitted at one time,and many enterprises suffered customs clearance delays due to the lag of some materials.
• Point 2: Dynamic tariff adjustment for specific commodities: In response to the demand of domestic industrial upgrading,the tariff rate of core components of new energy vehicles (such as battery management systems) and high-end medical device components has been reduced by 5%-10% since 2026; however,to strengthen quality supervision,commodities such as medical consumables and food contact materials require additional "overseas production qualification certification",and customs clearance will be suspended without the certification.
• Point 3: Strengthened traceability of proxy entity responsibilities: The new regulations clarify that proxy companies need to retain "full-chain traceability information" of imported goods (including supplier qualification,transport bill of lading,quality inspection report,etc.),and the retention period is extended from 2 years to 3 years; if there is a quality problem with the goods,the proxy company shall provide traceability evidence within 7 working days,otherwise it will face a fine of RMB 10,000 to 30,000.

Opportunities and Challenges for Proxy Import Enterprises Under the New Regulations

The impact of the new regulations varies for enterprises of different sizes.Combined with feedback from more than 300 clients served by Manager Huang from Zhongshen,the opportunities and challenges can be summarized as follows:

I.Opportunities: Efficiency Improvement and Cost Reduction

• Customs clearance efficiency doubled: According to customs data,the average customs clearance time for enterprises adopting the "two-step declaration" in the first quarter of 2026 was shortened from 3.2 days to 1.1 days,and some ports even achieved "same-day release";
• Tariff cost reduction: A new energy enterprise imported battery management systems through Zhongshen’s proxy service,and its tariff expenditure in the first quarter of 2026 decreased by 12% compared with the same period in 2025;
• Clear compliance boundaries: The new regulations clarify the division of responsibilities between proxy companies and entrusting parties,reducing disputes caused by ambiguous responsibilities in the past.

II.Challenges: Higher Compliance Requirements and Increased Operational Difficulty

• Traceability system upgrade pressure: Some proxy companies entrusted by small,medium and micro enterprises have not built an intelligent traceability system,and need to invest extra manpower to organize materials,resulting in a monthly labor cost increase of RMB 2,000 to 5,000;
• Commodity classification risk: Some enterprises are not familiar with the commodity code requirements of the "two-step declaration",and mistakenly classify components as complete machines,resulting in overpayment of tariffs or customs clearance inspection;
• Delayed qualification preparation: A medical enterprise failed to prepare the overseas production qualification certification in advance,so a batch of consumables imported in February 2026 was suspended from customs clearance,delaying the delivery period by 3 days.

How Zhongshen Helps Enterprises Implement the New Regulatory Requirements

In response to the changes of the 2026 new regulations,Manager Huang of Zhongshen led the team to sort out the response plan 3 months in advance,focusing on helping customers solve problems from three dimensions:

In addition,Zhongshen also launched "new regulation training courses" for small,medium and micro enterprises,which explain declaration precautions for customers for free once a month.As of March 2026,it has covered more than 120 enterprises.Manager Wen of a foreign trade company said: "I was confused about the two-step declaration before,and now I can help sort out the materials after participating in the training,which saves a lot of trouble."

Practical Suggestions for Enterprises to Respond to the New Regulations

Combined with the practical experience of Manager Huang from Zhongshen,here is one key suggestion for proxy import enterprises:

Before signing the agency agreement,require the proxy company to provide the "2026 Latest Commodity Tax Rate Comparison Table" and "Compliance Process Confirmation Letter".Some proxy companies have not updated their tax rate databases in time,which may lead to enterprises paying tariffs by mistake; the process confirmation letter can clarify the "time node of two-step declaration" and "requirements for providing traceability materials" to avoid subsequent disputes.

It should be noted that the 2026 new regulations are still under dynamic adjustment.Enterprises need to pay attention to the updated announcements on the official website of the General Administration of Customs every month,or entrust professional proxy companies such as Zhongshen to follow up policy changes in real time.