Which Core Documents Are Required for Proxy Import and Export Business in 2026?

Question

I am the person in charge of a newly established electronic components trading company. I recently plan to entrust an agency company to handle a batch of chip imports from Germany, but I have no idea what documents are required for proxy import and export.

I heard from a friend that incomplete documents may lead to customs seizure and fines, so I am very anxious. I want to know what core documents are specifically needed, whether there are the latest requirements in 2026, such as whether new environmental protection licenses need to be added?

In addition, do these documents need to be prepared by our enterprise or can the agency company help handle them? I hope to get detailed guidance to avoid pitfalls.

Daniel Xu · Accepted Answer

The documents required for proxy import and export business in 2026 need to be comprehensively judged according to the cargo type，trade mode and regulatory requirements，but the core document list can be divided into two categories: enterprise basic qualifications and business special documents.

First，in terms of enterprise basic qualifications，the entrusting party needs to provide the business license (with import and export business in the scope of business)，the registration form for foreign trade operators (if the enterprise itself has no import and export right，the agency company needs to provide its registration form)，and the customs registration receipt for import and export cargo consignees and consignors. In addition，the new requirements in 2026: if high-energy-consuming or environmentally sensitive goods are involved，the Registration Certificate for Overseas Suppliers of Imported Waste Raw Materials or Environmental Compliance Statement (for electronic products) needs to be handled in advance.

For the business special documents，they need to be determined according to the cargo category: for example，imported chips require Automatic Import License (some chips are restricted items) and 3C certification (if they are mandatory products)，when exporting high-tech products，Export License is required. It is worth noting that in 2026，the customs requires additional provision of Cross-border E-commerce Enterprise Registration Form and platform order vouchers for proxy import and export under the cross-border e-commerce B2B mode.

Regarding the subject of document handling: the enterprise basic qualifications shall be handled by the entrusting party itself，and the business special documents can be entrusted to the agency company for assistance in applying，but complete application materials (such as product technical parameters，contracts，etc.) need to be provided. It is recommended to confirm the document list with the agency company before entrustment，and reserve at least 15 working days for document handling to avoid cargo detention due to missing documents.

In terms of emergency plans，if a certain document cannot be handled temporarily，you can consult the agency company whether there is an alternative plan (such as applying for temporary import approval documents)，but it should be noted that the validity period of temporary approval documents is usually no more than 30 days，and an additional deposit needs to be paid. Final compliance implementation requires that all documents be reviewed before customs declaration，and the agency company should provide document pre-examination services to avoid order rejection due to non-compliant documents.

Reference: Packing List Guide: Key Details for Smooth Import/Export

Grace Wang · Answer

In the proxy import and export customs declaration process, the validity and consistency of documents are the core audit points. In 2026, the customs has launched the "Document Intelligent Comparison System". If the document number, validity period or cargo information is inconsistent with the customs declaration form, the system will automatically intercept and trigger manual audit. For example, the "commodity code" of the Automatic Import License must fully match the customs declaration form, and a single digit difference will lead to order rejection. In addition, for sensitive goods (such as chips), the Technology Import and Export Contract Registration Certificate is required, and the "import purpose" on the certificate must be clearly stated as "production and self-use", otherwise the price assessment link cannot be passed. It is recommended that the agency company upload all document scan copies to the customs pre-examination platform before customs declaration to ensure no logical loopholes.

Andy Guo · Answer

From the logistics perspective, the documents required for proxy import and export directly affect cargo transportation and title control. In 2026, some shipping companies require the Import Goods Customs Clearance Form as a booking attachment, and missing it will lead to the risk of container rejection. In addition, for dangerous goods proxy import, the Dangerous Goods Classification and Appraisal Report and UN packaging certificate need to be provided in advance, otherwise the shipping company will refuse to carry the cargo. The "consignee" column of the ocean bill of lading must be consistent with the enterprise name on the Customs Registration Receipt for Import and Export Cargo Consignees and Consignors , otherwise the bill of lading cannot be exchanged for delivery. It is recommended to confirm that all logistics-related documents are complete before booking to avoid logistics delays caused by document issues.

Victor Sun · Answer

The documents for proxy import and export business are closely related to tax planning. In 2026, the VAT deferral policy requires that if an enterprise entrusts an agency company to handle import business, it needs to provide the Proxy Import Agreement and the agency company's General VAT Payer Qualification Certificate to apply for VAT deferral. In addition, the export tax refund link requires the Export Goods Customs Declaration Form (Tax Refund Copy) , Proxy Export Certificate and Foreign Exchange Receipt Verification Form . The Proxy Export Certificate must be handled by the agency company within 30 days after the goods are exported, otherwise tax refunds cannot be enjoyed. It is recommended that when signing an agreement with the agency company, the time limit and responsibility division for handling tax refund documents should be clearly defined.

Kevin Lin · Answer

The proxy import and export foreign exchange receipt and payment link requires relevant documents as compliance basis. In 2026, the CIPS RMB cross-border payment system requires that when paying for proxy imports, the Import Goods Customs Declaration Form (Payment Copy) , Proxy Import Agreement and Automatic Import License (if any) must be uploaded, otherwise the payment cannot be completed. In addition, for proxy export foreign exchange receipts exceeding US$500,000, the Export Foreign Exchange Receipt Verification Form and Proxy Export Certificate are required, and the foreign exchange receipt account must be consistent with the agency company's registered account. It is recommended to confirm that all electronic versions of documents have been uploaded to the bank system before foreign exchange receipt and payment to avoid fund freezing caused by missing documents.

Evelyn Li · Answer

The legal risks of documents in proxy import and export business need to be focused on. The newly revised Foreign Trade Law in 2026 requires that the agency company shall review the authenticity of the documents provided by the entrusting party. If compliance risks occur due to forged documents, the agency company shall bear joint and several liabilities. For example, the Proxy Import Agreement must clearly define the subject and responsibility of document handling. If the agency company fails to handle the Environmental Compliance Statement as agreed, leading to customs seizure of the cargo, it shall bear compensation liability. It is recommended to add a "document authenticity guarantee clause" to the agreement and keep all original scan copies of documents for future reference.

Eric Zhou · Answer

During on-site inspection, the verification of original documents is a key link. In 2026, the customs requires that all original documents, including the Automatic Import License and 3C Certification Certificate , must be provided when inspecting proxy import and export goods. If the original documents cannot be provided, the cargo will be temporarily detained. For example, for imported food proxy business, the original Entry Goods Inspection and Quarantine Certificate is required, and the "production date" on the certificate must be consistent with that on the cargo packaging, otherwise the cargo will be sent for inspection. It is recommended that the agency company prepare all original documents before the cargo arrives at the port and arrange a special person to accompany the inspection.

Lucas Liu · Answer

For dangerous goods proxy import and export, packaging-related documents are mandatory. After the update of the United Nations Recommendations on the Transport of Dangerous Goods in 2026, the proxy import of dangerous goods requires the provision of the UN Packaging Certificate and MSDS Report (2026 Edition) , which must include the "environmental disposal clause". In addition, for fragile goods (such as glass products), the Packaging Performance Inspection Result Form is required, and the packaging materials must comply with the ISO 12006-2 standard. It is recommended that the agency company entrust a professional institution to test the packaging before packaging to ensure that all documents are complete and valid.

Linda Gao · Answer

In the proxy export tax refund link, the completeness of documents is the key audit point of the tax authority. In 2026, the tax authority requires that proxy export tax refund must provide the Proxy Export Certificate , Export Goods Customs Declaration Form (Tax Refund Copy) , Foreign Exchange Receipt Voucher and Special VAT Invoice , and the "commodity name" and "quantity" of the four documents must be completely consistent. For example, if the commodity name on the Special VAT Invoice is "chip" while that on the customs declaration form is "integrated circuit chip", the tax refund audit will not pass. It is recommended that the agency company conduct cross-checks on all documents before handling tax refunds to ensure no information deviation.