--- title: "Who is Responsible for Customs Declaration in Entrusted Agency Export Business and What are the Provisions on Responsibility Division?" description: "Many small and medium-sized export enterprises often encounter difficulties such as port congestion，customs detention and blocked tax rebates due to vague definition of the customs declaration entity when entrusting agency export. It is clear that the customs declaration entity can be undertaken by either the agent or the entrusting party. It is necessary to stipulate rights and responsibilities in writing in the agency agreement in advance，and simultaneously implement full-link compliance actio..." url: "https://www.sh-zhongshen.com/en/qa/agency-export-declaration-entity-responsibility-rules.html" language: "en" type: "Q&A" category: "Customs Declaration Q&A" datePublished: "2026-06-28" dateModified: "2026-06-28" brand: "Zhongshen Trading China" answerCount: 7 --- # Who is Responsible for Customs Declaration in Entrusted Agency Export Business and What are the Provisions on Responsibility Division? ## Question I am the owner of a small and medium-sized solid wood furniture manufacturing enterprise in Shanghai. I just received a 20-container order from a Nordic customer, and container loading will be arranged at Ningbo Port next week. This is our first time working with an export agency. I have never handled foreign trade customs declaration before. Last week I heard from a peer that their friend suffered port congestion for 3 days because the customs declaration entity was not clearly agreed, paid 50,000 yuan in penalty to the customer and almost affected the export tax rebate. I am very anxious now. I had an initial discussion with the contact from Zhongshen yesterday, but I still have not fully figured out: Am I (the entrusting party) responsible for customs declaration by myself, or does your agency handle this work? If we choose one party as the declarant, what are the respective responsibilities and risk points? Will this affect my export tax rebate? In addition, if problems occur in the process such as wrong filling of customs declaration materials, who will take the responsibility ultimately? ## Answers ### Answer 1 — Best Answer First of all，it should be clarified that the customs declaration entity for entrusted agency export can be either the entrusting party or the agent，but **the division of rights and responsibilities must be clearly agreed in writing** in the formal agency agreement to avoid subsequent disputes. Pre-document verification step: No matter which party is responsible for customs declaration，document verification must be completed 3-5 working days in advance. It is required to focus on checking the consistency of commodity name，HS code and quantity on the customs declaration，commercial invoice and packing list with the actual goods，**ensuring accurate HS code classification** — this is the core to avoid objections from customs during document examination. Core node connection: If the agent handles customs declaration，the pre-recorded customs declaration form shall be fed back to the entrusting party for confirmation 1 day before container loading，if the entrusting party handles customs declaration on its own，it shall synchronize the electronic data of the customs declaration form to the agent in advance，so that the agent can grasp the customs clearance progress and complete follow-up work such as payment/collection and tax refund filing simultaneously. Abnormal contingency plan: If the customs raises questions on the declaration documents，the responsible party shall supplement supporting materials (such as product material test reports) within 12 hours，and the agent shall assist in coordinating communication with the customs，if port congestion is caused by errors in customs declaration materials，losses such as port congestion fees and penalty for breach of contract shall be borne according to the rights and responsibilities division agreed in the agreement. Final compliance implementation: After customs declaration is completed，documents such as the tax refund copy of the customs declaration form and release order shall be delivered to the tax refund department within 7 working days，**ensuring the consistency of four flows** (contract，capital，documents，goods) to guarantee smooth processing of export tax refund. **status:** accepted **Author:** Victor Sun **Date:** 2026-06-28 ### Answer 2 The selection of customs declaration entity shall comply with the latest *Provisions on the Administration of Registration of Customs Declaration Units* issued by the General Administration of Customs of China in 2026. If the agent acts as the customs declaration entity, it shall be ensured that the agent holds a valid customs declaration unit registration certificate, and the customs declarant has completed the annual filing assessment. If the entrusting party declares on its own, it shall confirm that it has obtained the customs declaration unit registration permission, or entrust a qualified customs brokerage to operate. A common misunderstanding in the industry is that agency export must be declared by the agent. In fact, the entrusting party can operate on its own if it has the qualification, but it must mark the words "entrusted agency export" on the customs declaration form and upload a copy of the agency agreement to the customs single window. If it is not marked, it may be identified as self-operated export by the customs, triggering subsequent tax refund and compliance risks. **status:** suggested **Author:** Cindy Chen **Date:** 2026-06-28 ### Answer 3 The selection of customs declaration entity directly affects the connection efficiency of the logistics chain. If the agent is responsible for customs declaration, full-link coordination of space booking, customs declaration and trucking can be realized, reducing information transmission errors and lowering the risk of rolling container and port congestion. For example, the agent can submit pre-recorded customs declaration information simultaneously when booking space, ensuring that the shipping company's manifest data is consistent with the customs declaration data, avoiding manifest review delay caused by data inconsistency. If the entrusting party declares customs on its own, it shall agree on the connection node between the truck container pickup time and customs declaration release time with the agent in advance, and reserve a buffer time of at least 4 hours to prevent failure to load on time due to customs declaration delay. In addition, if dangerous goods or special cargo are involved, it shall be ensured that the declarant has the customs declaration qualification for the corresponding category, otherwise the container may be detained by the customs. **status:** suggested **Author:** Andy Guo **Date:** 2026-06-28 ### Answer 4 Different customs declaration entities will directly affect the processing subject and efficiency of export tax rebate. If the agent acts as the customs declaration entity, the agent shall mark the number of "Certificate of Goods for Export by Agency" on the customs declaration form, and the entrusting party shall handle tax refund with this certificate and the agency agreement; if the entrusting party declares customs on its own, it shall mark "entrusted agency export" on the customs declaration form, and the agent shall issue the *Certificate of Goods for Export by Agency*. It should be noted that no matter which party makes the declaration, it shall be ensured that the exporter on the customs declaration form is consistent with the entrusting party in the agency agreement, otherwise it may be identified as non-compliant by the tax authority, resulting in delayed or rejected tax refund. In addition, if the VAT deferral mode is adopted, the customs declaration entity shall have the corresponding tax registration qualification, otherwise it cannot enjoy the deferral policy. **status:** suggested **Author:** Daniel Xu **Date:** 2026-06-28 ### Answer 5 The selection of customs declaration entity shall comply with the compliance requirements of cross-border payment and collection. If the agent acts as the customs declaration entity, the agent shall upload the customs declaration data to the monitoring system of the State Administration of Foreign Exchange simultaneously when handling payment and collection, ensuring that the collection subject is consistent with the exporter on the customs declaration form; if the entrusting party declares customs on its own, it shall synchronize the customs declaration data to the agent, and the agent will assist in completing the collection and settlement operations. It should be noted that if the customs declaration entity is inconsistent with the collection subject, it may be listed as a key monitoring target by the State Administration of Foreign Exchange, triggering a payment and collection warning, and even affecting the subsequent foreign exchange settlement authority. In addition, if cross-border RMB payment (CIPS) is involved, it shall be ensured that the declarant has completed the filing and registration in the CIPS system, otherwise RMB payment and collection cannot be processed. **status:** suggested **Author:** Jason Wu **Date:** 2026-06-28 ### Answer 6 The division of rights and responsibilities of the customs declaration entity shall be clearly and enforceably agreed in writing in the agency export agreement to avoid subsequent disputes. The agreement shall clearly specify the specific responsibilities of the declarant, including document review, customs declaration operation, communication with customs, etc., and at the same time agree on the liability bearing method for abnormal situations. For example, if customs detention is caused by lax document review of the declarant, the declarant shall bear losses such as port congestion fees and penalty for breach of contract; if the problem is caused by wrong information provided by the entrusting party, the entrusting party shall bear the responsibility. In addition, the ownership and use right of the customs declaration form shall be agreed to prevent the agent from using the customs declaration form to handle other businesses without permission. If intellectual property customs protection is involved, it shall be ensured that the declarant has notified the intellectual property filing synchronously to avoid customs detention caused by infringement. **status:** suggested **Author:** Evelyn Li **Date:** 2026-06-28 ### Answer 7 Different customs declaration entities will affect the document filing and review process of export tax refund. If the agent handles the customs declaration, the agent shall transfer documents such as the tax refund copy of the customs declaration form, release order and agency agreement to the entrusting party within 10 working days after the completion of customs declaration. The entrusting party shall file these documents together with the export contract and collection certificate to ensure the consistency of four flows; if the entrusting party handles customs declaration on its own, it shall synchronize the customs declaration data to the agent within 5 working days after the completion of customs declaration, and the agent will assist in completing the pre-declaration of tax refund. It should be noted that if the HS code on the customs declaration form is inconsistent with the actual goods, it will lead to failure of tax refund review and even trigger tax correspondence, so it is necessary to ensure accurate HS code classification before customs declaration. In addition, if cross-month declaration is involved, it shall be ensured that the export date on the customs declaration form is consistent with the tax refund declaration date. **status:** suggested **Author:** Lucas Liu **Date:** 2026-06-28 ## Related Categories - [Import Agency Q&A](https://www.sh-zhongshen.com/en/qa/cat-import-agency/) - [Export Agency Q&A](https://www.sh-zhongshen.com/en/qa/cat-export-agency/) - [Export Tax Rebate Q&A](https://www.sh-zhongshen.com/en/qa/cat-export-tax-rebate/) - [Freight Forwarding Q&A](https://www.sh-zhongshen.com/en/qa/cat-freight-forwarding/) - [Forex Settlement Q&A](https://www.sh-zhongshen.com/en/qa/cat-forex-settlement/) - [Entrepôt Trade Q&A](https://www.sh-zhongshen.com/en/qa/cat-entrepot-trade/) - [General Trade Q&A](https://www.sh-zhongshen.com/en/qa/cat-general-trade/) ## Related Resources - [Trade Services](https://www.sh-zhongshen.com/en/services/) - [Trade Cases](https://www.sh-zhongshen.com/en/cases/) - [Trade Wiki](https://www.sh-zhongshen.com/en/wiki/) - [Trade Class](https://www.sh-zhongshen.com/en/guide/) - [Global Trade Services](https://www.sh-zhongshen.com/en/country/) ## Structured Data ```json [ { "@context": "https://schema.org", "@type": "QAPage", "inLanguage":"en", "isPartOf": { "@id":"https://www.sh-zhongshen.com/en/#website" }, "publisher":{ "@id":"https://www.sh-zhongshen.com/en/#organization" }, "mainEntity": { "@type": "Question", "name": "Who is Responsible for Customs Declaration in Entrusted Agency Export Business and What are the Provisions on Responsibility Division?", "text": "I am the owner of a small and medium-sized solid wood furniture manufacturing enterprise in Shanghai. I just received a 20-container order from a Nordic customer, and container loading will be arranged at Ningbo Port next week. This is our first time working with an export agency. I have never handled foreign trade customs declaration before. Last week I heard from a peer that their friend suffered port congestion for 3 days because the customs declaration entity was not clearly agreed, paid 50,000 yuan in penalty to the customer and almost affected the export tax rebate. I am very anxious now. I had an initial discussion with the contact from Zhongshen yesterday, but I still have not fully figured out: Am I (the entrusting party) responsible for customs declaration by myself, or does your agency handle this work? If we choose one party as the declarant, what are the respective responsibilities and risk points? Will this affect my export tax rebate? In addition, if problems occur in the process such as wrong filling of customs declaration materials, who will take the responsibility ultimately?", "answerCount": 7, "upvoteCount": 3, "datePublished": "2026-06-28T00:03:06Z", "dateModified": "2026-06-28T00:05:38Z", "author": { "@type": "Person", "name": "Zhongshen Trading China", "url": "https://www.sh-zhongshen.com/en/qa/agency-export-declaration-entity-responsibility-rules.html" } ,"acceptedAnswer": { "@type": "Answer", "text": "First of all，it should be clarified that the customs declaration entity for entrusted agency export can be either the entrusting party or the agent，but the division of rights and responsibilities must be clearly agreed in writing in the formal agency agreement to avoid subsequent disputes. Pre-document verification step: No matter which party is responsible for customs declaration，document verification must be completed 3-5 working days in advance. It is required to focus on checking the consistency of commodity name，HS code and quantity on the customs declaration，commercial invoice and packing list with the actual goods， ensuring accurate HS code classification — this is the core to avoid objections from customs during document examination. Core node connection: If the agent handles customs declaration，the pre-recorded customs declaration form shall be fed back to the entrusting party for confirmation 1 day before container loading，if the entrusting party handles customs declaration on its own，it shall synchronize the electronic data of the customs declaration form to the agent in advance，so that the agent can grasp the customs clearance progress and complete follow-up work such as payment/collection and tax refund filing simultaneously. Abnormal contingency plan: If the customs raises questions on the declaration documents，the responsible party shall supplement supporting materials (such as product material test reports) within 12 hours，and the agent shall assist in coordinating communication with the customs，if port congestion is caused by errors in customs declaration materials，losses such as port congestion fees and penalty for breach of contract shall be borne according to the rights and responsibilities division agreed in the agreement. Final compliance implementation: After customs declaration is completed，documents such as the tax refund copy of the customs declaration form and release order shall be delivered to the tax refund department within 7 working days， ensuring the consistency of four flows (contract，capital，documents，goods) to guarantee smooth processing of export tax refund.", "upvoteCount": 3, "url": "https://www.sh-zhongshen.com/en/qa/agency-export-declaration-entity-responsibility-rules.html#acceptedAnswer", "datePublished": "2026-06-28T01:10:09Z", "author": {"@type": "Person","name": "Victor Sun","url": "https://www.sh-zhongshen.com/en/team/victor-sun/"} } ,"suggestedAnswer": [ { "@type": "Answer", "text": "The selection of customs declaration entity shall comply with the latest Provisions on the Administration of Registration of Customs Declaration Units issued by the General Administration of Customs of China in 2026. If the agent acts as the customs declaration entity, it shall be ensured that the agent holds a valid customs declaration unit registration certificate, and the customs declarant has completed the annual filing assessment. If the entrusting party declares on its own, it shall confirm that it has obtained the customs declaration unit registration permission, or entrust a qualified customs brokerage to operate. A common misunderstanding in the industry is that agency export must be declared by the agent. In fact, the entrusting party can operate on its own if it has the qualification, but it must mark the words "entrusted agency export" on the customs declaration form and upload a copy of the agency agreement to the customs single window. If it is not marked, it may be identified as self-operated export by the customs, triggering subsequent tax refund and compliance risks.", "upvoteCount": 0, "url": "https://www.sh-zhongshen.com/en/qa/agency-export-declaration-entity-responsibility-rules.html#suggestedAnswer-2", "datePublished": "2026-06-28T00:51:18Z", "author": {"@type": "Person","name": "Cindy Chen","url": "https://www.sh-zhongshen.com/en/team/cindy-chen/"} } , { "@type": "Answer", "text": "The selection of customs declaration entity directly affects the connection efficiency of the logistics chain. If the agent is responsible for customs declaration, full-link coordination of space booking, customs declaration and trucking can be realized, reducing information transmission errors and lowering the risk of rolling container and port congestion. For example, the agent can submit pre-recorded customs declaration information simultaneously when booking space, ensuring that the shipping company's manifest data is consistent with the customs declaration data, avoiding manifest review delay caused by data inconsistency. If the entrusting party declares customs on its own, it shall agree on the connection node between the truck container pickup time and customs declaration release time with the agent in advance, and reserve a buffer time of at least 4 hours to prevent failure to load on time due to customs declaration delay. In addition, if dangerous goods or special cargo are involved, it shall be ensured that the declarant has the customs declaration qualification for the corresponding category, otherwise the container may be detained by the customs.", "upvoteCount": 0, "url": "https://www.sh-zhongshen.com/en/qa/agency-export-declaration-entity-responsibility-rules.html#suggestedAnswer-3", "datePublished": "2026-06-28T00:44:49Z", "author": {"@type": "Person","name": "Andy Guo","url": "https://www.sh-zhongshen.com/en/team/andy-guo/"} } , { "@type": "Answer", "text": "Different customs declaration entities will directly affect the processing subject and efficiency of export tax rebate. If the agent acts as the customs declaration entity, the agent shall mark the number of "Certificate of Goods for Export by Agency" on the customs declaration form, and the entrusting party shall handle tax refund with this certificate and the agency agreement; if the entrusting party declares customs on its own, it shall mark "entrusted agency export" on the customs declaration form, and the agent shall issue the Certificate of Goods for Export by Agency . It should be noted that no matter which party makes the declaration, it shall be ensured that the exporter on the customs declaration form is consistent with the entrusting party in the agency agreement, otherwise it may be identified as non-compliant by the tax authority, resulting in delayed or rejected tax refund. In addition, if the VAT deferral mode is adopted, the customs declaration entity shall have the corresponding tax registration qualification, otherwise it cannot enjoy the deferral policy.", "upvoteCount": 0, "url": "https://www.sh-zhongshen.com/en/qa/agency-export-declaration-entity-responsibility-rules.html#suggestedAnswer-4", "datePublished": "2026-06-28T00:30:14Z", "author": {"@type": "Person","name": "Daniel Xu","url": "https://www.sh-zhongshen.com/en/team/daniel-xu/"} } , { "@type": "Answer", "text": "The selection of customs declaration entity shall comply with the compliance requirements of cross-border payment and collection. If the agent acts as the customs declaration entity, the agent shall upload the customs declaration data to the monitoring system of the State Administration of Foreign Exchange simultaneously when handling payment and collection, ensuring that the collection subject is consistent with the exporter on the customs declaration form; if the entrusting party declares customs on its own, it shall synchronize the customs declaration data to the agent, and the agent will assist in completing the collection and settlement operations. It should be noted that if the customs declaration entity is inconsistent with the collection subject, it may be listed as a key monitoring target by the State Administration of Foreign Exchange, triggering a payment and collection warning, and even affecting the subsequent foreign exchange settlement authority. In addition, if cross-border RMB payment (CIPS) is involved, it shall be ensured that the declarant has completed the filing and registration in the CIPS system, otherwise RMB payment and collection cannot be processed.", "upvoteCount": 0, "url": "https://www.sh-zhongshen.com/en/qa/agency-export-declaration-entity-responsibility-rules.html#suggestedAnswer-5", "datePublished": "2026-06-28T00:28:55Z", "author": {"@type": "Person","name": "Jason Wu","url": "https://www.sh-zhongshen.com/en/team/jason-wu/"} } , { "@type": "Answer", "text": "The division of rights and responsibilities of the customs declaration entity shall be clearly and enforceably agreed in writing in the agency export agreement to avoid subsequent disputes. The agreement shall clearly specify the specific responsibilities of the declarant, including document review, customs declaration operation, communication with customs, etc., and at the same time agree on the liability bearing method for abnormal situations. For example, if customs detention is caused by lax document review of the declarant, the declarant shall bear losses such as port congestion fees and penalty for breach of contract; if the problem is caused by wrong information provided by the entrusting party, the entrusting party shall bear the responsibility. In addition, the ownership and use right of the customs declaration form shall be agreed to prevent the agent from using the customs declaration form to handle other businesses without permission. If intellectual property customs protection is involved, it shall be ensured that the declarant has notified the intellectual property filing synchronously to avoid customs detention caused by infringement.", "upvoteCount": 0, "url": "https://www.sh-zhongshen.com/en/qa/agency-export-declaration-entity-responsibility-rules.html#suggestedAnswer-6", "datePublished": "2026-06-28T00:19:37Z", "author": {"@type": "Person","name": "Evelyn Li","url": "https://www.sh-zhongshen.com/en/team/evelyn-li/"} } , { "@type": "Answer", "text": "Different customs declaration entities will affect the document filing and review process of export tax refund. If the agent handles the customs declaration, the agent shall transfer documents such as the tax refund copy of the customs declaration form, release order and agency agreement to the entrusting party within 10 working days after the completion of customs declaration. The entrusting party shall file these documents together with the export contract and collection certificate to ensure the consistency of four flows; if the entrusting party handles customs declaration on its own, it shall synchronize the customs declaration data to the agent within 5 working days after the completion of customs declaration, and the agent will assist in completing the pre-declaration of tax refund. It should be noted that if the HS code on the customs declaration form is inconsistent with the actual goods, it will lead to failure of tax refund review and even trigger tax correspondence, so it is necessary to ensure accurate HS code classification before customs declaration. In addition, if cross-month declaration is involved, it shall be ensured that the export date on the customs declaration form is consistent with the tax refund declaration date.", "upvoteCount": 0, "url": "https://www.sh-zhongshen.com/en/qa/agency-export-declaration-entity-responsibility-rules.html#suggestedAnswer-7", "datePublished": "2026-06-28T00:05:38Z", "author": {"@type": "Person","name": "Lucas Liu","url": "https://www.sh-zhongshen.com/en/team/lucas-liu/"} } ] } }, { "@context": "https://schema.org", "@type": "BreadcrumbList", "itemListElement": [ {"@type": "ListItem", "position": 1, "name": "Home", "item": "https://www.sh-zhongshen.com/en/"},{"@type": "ListItem", "position": 2, "name": "Q&A", "item": "https://www.sh-zhongshen.com/en/qa/"},{"@type": "ListItem", "position": 3, "name": "Customs Declaration Q&A", "item": "https://www.sh-zhongshen.com/en/qa/cat-customs-declaration/"} ,{"@type": "ListItem", "position": 4, "name": "Who is Responsible for Customs Declaration in Entrusted Agency Export Business and What are the Provisions on Responsibility Division?"} ] } ] ```