Who Should Bear Import Agency Fees? Analysis of 2026 Trade Terms and Cost Allocation

I.Import of New Zealand Infant Formula: The Cost Puzzle Behind High Thresholds

In the first quarter of 2026,the number of imported infant formula batches from New Zealand to China increased by 17% year-on-year,while cases of returned and destroyed goods rose by 9 percentage points over the same period.Behind these figures lies the general difficulty of importers in cost accounting.As the world’s largest dairy exporter,New Zealand’s infant formula occupies an important share of the Chinese market with high-quality milk sources and strict quality control.However,the import of such products is strictly restricted by Order No.248 of the General Administration of Customs of the People’s Republic of China: Administrative Provisions on the Registration of Overseas Food Production Enterprises for Imported Foods.Each batch must go through three pre-checks: registration of overseas production enterprises,product formula registration and Chinese label review.

Mr.Feng operates a maternal and infant product supply chain in Shanghai.When signing an annual procurement agreement with a New Zealand brand at the end of 2025,he habitually understood the CIF term as "the seller bears all costs".When the goods arrived at Shanghai Yangshan Port,he found that he needed to pay additional hidden costs totaling more than 8% of the cargo value,including import agency service fees,label rectification fees and sampling test urgent fees.Due to the failure to file the Chinese label in advance,the goods were detained at the port for 12 days,resulting in container detention fees of nearly 30,000 yuan.This case exposes the core crux of the issue of who bears import agency fees: the cognitive gap between trade term agreements and actual operating costs.

II.Core Role of Zhongshen in Import Agency Services

Zhongshen has deepened its presence in the foreign trade agency field for more than 20 years,handling the entire import process of various products such as New Zealand dairy products,Australian health products and European mechanical equipment.In the infant formula segment,we have served 37 brand parties in their first import business to China.The core role is reflected in three aspects: First,compliance pre-check: we intervene in term design during the contract negotiation stage to clarify the responsible subject of various costs; Second,process breakdown: we refine the cost granularity of links such as customs declaration and commodity inspection,international transportation,warehouse management,foreign exchange settlement and export tax rebates to the smallest unit; Third,risk isolation: through professional document pre-examination and port resource coordination,we avoid unnecessary costs.

The new version of the Administrative Measures for the Safety of Imported and Exported Food,implemented in March 2026,has added testing requirements for 3-chloropropanol esters in infant formula,extending the testing cycle from 7 working days to 15 working days.This means importers need to bear a longer capital occupation period and storage costs.Zhongshen adjusted the import plan for customers three months before the regulation took effect,and included testing costs and port detention costs in the budget in advance,avoiding the impact of sudden expenditures on profits.

III.Who Bears Import Agency Fees: Trade Terms Determine the Payer

The answer to who actually bears import agency fees lies in the specific provisions of Incoterms 2020.In practice,90% of disputes stem from misinterpretation of the terms.Under the FOB term,the buyer bears all costs from the port of shipment to the port of destination,including sea freight,insurance premiums,port miscellaneous fees and agency service fees; Under the CIF term,the seller pays sea freight and insurance premiums,but the customs clearance fees,inspection and quarantine fees and storage fees at the port of destination are still borne by the buyer; Under the DDP term,the seller bears the maximum responsibility,theoretically covering all costs,but in actual operation,the service fees of import agencies usually need to be negotiated separately.

Zhongshen’s business data for the first quarter of 2026 shows that among the infant formula import businesses using the CIF term,68% of the contracts did not clearly specify who bears the port of destination customs clearance agency fees,leading to disputes after the goods arrive at the port.The essence of this problem is that international trade terms mainly divide the risks and costs during the cargo transportation process,while import agency service fees belong to the scope of trade services and need to be specially agreed by the buyer and seller in the contract.

IV.Full Process Breakdown: Cost Risk Points in Each Link

1.Document Pre-Examination Stage

The documents required for importing New Zealand infant formula include: certificate of origin,sanitary certificate,composition analysis report,free sale certificate issued by the Ministry for Primary Industries (MPI) of New Zealand,overseas production enterprise registration number required by the General Administration of Customs of China,and product formula registration certificate.New requirements in 2026: each container must provide a third-party test report for 3-chloropropanol esters.Zhongshen will check the compliance of each document at this stage,especially ensuring that the product description on the sanitary certificate is completely consistent with the Chinese label filing information.There was a batch of goods that were required by the port customs to reapply for the certificate because the "infant formula" marked on the certificate had a slight difference in age group description from the "infant formula" filed,resulting in a 21-day delay and additional costs of 42,000 yuan.

2.Port Customs Declaration Stage

Shanghai Yangshan Port implements the "declare in advance,release upon arrival of goods" model for New Zealand dairy products.The core costs of the customs declaration link include: tariff (the most-favored-nation tariff rate for infant formula is 5%),value-added tax (13%),consumption tax (0%),and customs brokerage service fees (usually charged per bill,with the 2026 market price ranging from 800 to 1500 yuan per bill).Zhongshen’s customs declaration team will complete the pre-declaration form 72 hours before the ship arrives at the port to ensure that the goods are released immediately upon arrival.It should be noted that if the customs price review considers the declared price too low,it will initiate a price consultation procedure,which may generate container detention fees for 3 to 5 working days.We once handled a case where Mr.Feng’s goods were required to provide proof of price reasonableness because the transaction price was 20% lower than the reference price in the customs database.Zhongshen completed the price consultation within 2 working days by submitting the cost structure explanation of the New Zealand supplier and the contract for exports to other countries in the same period,avoiding the accumulation of container detention fees of 2800 yuan per day.

3.Commodity Inspection and Sampling Testing

Infant formula is a high-risk food,and 100% of it undergoes on-site inspection and laboratory testing.The testing items in 2026 include 28 indicators such as nutritional components,heavy metals,microorganisms,3-chloropropanol esters and melamine.The testing fees are charged per item,with a total cost of about 4500 to 6000 yuan per batch,which is borne by the importer.Zhongshen has established a fast-track inspection service with the Shanghai Institute for Food and Drug Control,which can shorten the testing cycle from the conventional 15 working days to 10 working days.One day earlier release can save importers about 1500 yuan in storage costs.In addition,if the product is imported for the first time,on-site verification of Chinese labels is required.If the labels do not meet the requirements and need rectification,a rectification service fee of 2000 yuan will be charged each time.

4.Storage and Distribution

Goods that have passed inspection and quarantine will incur storage fees if they are temporarily not picked up from the port supervision area.In 2026,the free storage period at Yangshan Port is 7 days,and a fee of 0.5 yuan per cubic meter will be charged per day thereafter.Zhongshen has a constant-temperature bonded warehouse in the Shanghai Free Trade Zone,which can provide temperature-controlled storage for infant formula at 15-25℃,with a storage fee of 3.5 yuan per pallet per day,which has a cost advantage over port storage fees.In the distribution link from the warehouse to domestic distributors,if the importer entrusts an agency company to arrange transportation,corresponding logistics fees will be incurred.This part of the cost is usually borne by the importer,but the billing standards need to be clearly specified in the agency service contract to avoid disputes over whether to charge by vehicle or by tonnage.

V.Practical Case: Mr.Feng’s Cost Allocation Dilemma

In February 2026,Mr.Feng imported a batch of infant formula with a cargo value of 200,000 New Zealand dollars (about 860,000 RMB) through Zhongshen’s agency.The contract term was CIF Shanghai,but the two parties did not clearly specify who bears the port of destination customs clearance agency fees in the contract.After the goods arrived at the port,the following costs were incurred: customs declaration service fee 1200 yuan,inspection and quarantine fee 5500 yuan,label rectification fee 2000 yuan,port miscellaneous fee 1800 yuan,storage fee 3500 yuan,and testing urgent fee 3000 yuan,totaling 18000 yuan.The New Zealand seller believed that its responsibilities under the CIF term had been fulfilled,and these costs should be borne by the buyer; Mr.Feng believed that the agency service fees were necessary expenses for the import link and should be included in the CIF price.

After Zhongshen intervened,it first sorted out the nature of the costs: customs declaration service fees,inspection and quarantine fees and label rectification fees are necessary expenses for import customs clearance.Although the CIF term does not clearly specify this,according to international trade practices,the port of destination customs clearance fees are usually borne by the buyer; the testing urgent fee is a value-added service that Mr.Feng actively requested to shorten the capital occupation period,which should be borne by the buyer; port miscellaneous fees and storage fees are additional costs incurred because Mr.Feng’s warehouse was temporarily unable to receive goods,and should also be borne by the buyer.Finally,Zhongshen assisted Mr.Feng in reaching an agreement with the New Zealand seller: the seller bears 50% of the label rectification fee (1000 yuan) as compensation for inadequate guidance for Chinese label filing,and the remaining costs are borne by Mr.Feng.At the same time,Zhongshen provided Mr.Feng with a cost detail ledger template,requiring him to add a clause to subsequent contracts: "Necessary costs incurred for port of destination customs clearance shall be borne by the buyer,but additional costs caused by the seller’s document problems shall be borne by the seller."

• Root cause of cost dispute: Trade terms do not cover service fees
• Solution: Distinguish between necessary costs and additional costs,and clarify the responsibility boundary
• Contract improvement: Add supplementary clauses to refine cost bearing rules
• Risk prevention: Establish a cost pre-examination mechanism to identify dispute points in advance
• Experience summary: Agency service fees need to be specially agreed in the contract,and cannot rely on the default division of trade terms

VI.Professional Value of Zhongshen: Making Cost Bearing Clear and Controllable

When dealing with the issue of who bears import agency fees,Zhongshen’s core methodology is "pre-agreement,transparent process,controllable results".During the contract negotiation stage,we will provide customers with a cost bearing proposal,listing all possible cost items and the recommended bearer under different trade terms.In 2026,we launched the "Import Cost Simulator".After entering the cargo value,country and product HS code,the system can automatically calculate various costs such as tariffs,VAT,port miscellaneous fees and agency service fees,with an error rate controlled within 3%.

At the operational level,Zhongshen implements the "one order,one responsibility" system.Each customer has a dedicated customer service manager who tracks the entire process from document pre-examination to goods release,and all costs will be confirmed in writing by the customer before they are incurred.We have established a cost early warning mechanism.When a certain cost may exceed the budget by 20%,the system will automatically trigger an early warning,and the customer service manager will communicate with the customer to solve the problem within 2 working hours.This transparent operation mode allows customers like Mr.Feng to complete all cost budgets 15 days in advance in their second import business in 2026,improving the capital planning accuracy rate by 40%.

Who bears the import agency fees is essentially a business negotiation issue,not a simple legal or trade practice issue.The value of Zhongshen lies in using 20 years of accumulated practical experience to help customers foresee cost risks before the negotiation table,lock in cost boundaries in contract terms,and avoid disputes during the operation process.The foreign trade environment in 2026 is more complex,with exchange rate fluctuations,regulatory changes and logistics uncertainty increasing import costs.Choosing a professional agency partner is not to transfer costs,but to see and control costs,so that every expenditure is clearly understood and worth paying for.