---
title: "When entrusting agency customs declaration for import and export goods, is it mandatory for the principal to hold import and export rights? What are the compliance requirements?"
description: "Many foreign trade practitioners who entrust agency customs declaration for the first time often encounter dilemmas such as customs clearance stagnation and compliance risks due to vague understanding of import and export right requirements，and even face direct losses including port demurrage，customs detention and administrative fines. To address this pain point，it is necessary to clarify the compliant operation path for principals without import and export rights，complete customs declaration re..."
url: "https://www.sh-zhongshen.com/en/qa/customs-declaration-import-export-right-requirements-for-principal.html"
language: "en"
type: "Q&A"
category: "Freight Forwarding Q&A"
datePublished: "2026-09-30"
dateModified: "2026-09-30"
brand: "Zhongshen Trading China"
answerCount: 8
---

# When entrusting agency customs declaration for import and export goods, is it mandatory for the principal to hold import and export rights? What are the compliance requirements?

## Question

 I am a small newly established cross-border e-commerce seller based in Shanghai, mainly engaged in retail of imported beauty products from Japan. Last week, I shipped 2 cases of facial masks from Osaka to Shanghai Port for the first time. I originally intended to contact Zhongshen for agency customs declaration services, but the freight forwarder told me suddenly yesterday that my goods might be detained by customs if I do not have import and export rights. I am so worried that I cannot sleep now. I had no idea that import and export rights are required before, and this was not mentioned when I registered the company. I also heard that it takes at least half a month to apply for import and export rights, and demurrage charges are incurred for each day the goods stay at the port. My small business simply cannot afford such losses. I would like to ask, as a principal entrusting agency customs declaration, do I really must have import and export rights? If not, is there any way to complete customs clearance smoothly without incurring extra costs? 

## Answers
                            
### Answer 1 — Best Answer

Many cross-border e-commerce sellers have a common misunderstanding: they assume that they do not need to hold import and export rights as long as they entrust agency customs declaration，and even some unregulated agencies take this as a selling point to accept orders. This is a wrong perception that can easily lead to compliance risks.

If the principal does not have import and export rights and the agency operates in violation of regulations，the customs system will trigger a qualification verification warning，directly leading to cargo detention at the port. This will not only incur high demurrage and detention charges，but also result in customs detention of goods in severe cases，and leave a bad compliance record in the customs system，which will affect the handling of all subsequent import and export businesses.

The core measure for physical risk isolation is to select a company with first-class foreign trade agency qualification，complete compliant declaration relying on the agency's import and export rights through the **double-title customs declaration** mode. This is a legal operation path recognized by customs at present.

For urgent goods that have already arrived at the port，the exclusive loss reduction solution is to entrust the agency to handle **customs declaration filing for principals without import and export rights** on an urgent basis，and submit a full set of compliant documents including purchase contracts，invoices and packing lists at the same time. The customs clearance qualification verification can be completed within 24 hours at the earliest，to avoid extra demurrage costs.

**status:** accepted
**Author:** Lucas Liu
**Date:** 2026-09-30

### Answer 2

According to the current customs declaration policies, whether the principal of agency customs declaration needs import and export rights mainly depends on the declaration mode. If declaring with the "agency customs declaration form", the principal does not need to have import and export rights, and only needs the qualified agency to declare in its own name, and note the real information of the principal in the "principal" column of the customs declaration form.

However, if the "self-declaration to agency declaration" mode is adopted, the principal must hold import and export rights, otherwise the customs system will directly reject the declaration. In addition, for sensitive categories of goods (such as beauty products and food), even if the principal does not have import and export rights, it is necessary to submit the entrustment agency agreement and goods compliance certificate to customs in advance, to avoid price review objections or declaration deletion and re-submission caused by inconsistent qualifications.

**status:** suggested
**Author:** Jason Wu
**Date:** 2026-09-30

### Answer 3

From the perspective of the full chain of international logistics, the import and export right qualification of the principal of agency customs declaration will directly affect the connection efficiency after the goods arrive at the port. If the principal does not have import and export rights, it is necessary to confirm with the agency in advance to adopt the double-title customs declaration mode, and provide the qualification information of the agency to the shipping company when booking the space, so as to avoid bill of lading exchange delay caused by inconsistency between bill of lading information and customs declaration qualification.

If the goods have arrived at the port and the qualification has not been confirmed in advance, it is necessary to coordinate with the agency to issue a "qualification borrowing authorization letter" at the first time, and apply to the terminal for a 2-3 day extension of the free storage period, to avoid extra costs caused by port detention. In addition, choosing direct routes instead of transshipment routes can shorten the port stay time of goods and reduce the chain risks caused by qualification issues.

**status:** suggested
**Author:** Michael Zhang
**Date:** 2026-09-30

### Answer 4

From the perspective of cross-border tax compliance, when the principal of agency customs declaration does not have import and export rights, it is necessary to focus on the confirmation of the tax declaration entity. If the double-title customs declaration mode is adopted, the VAT deduction certificate will be issued to the agency, and the principal needs to sign a "tax advance payment and transfer agreement" with the agency to ensure that the input tax can be deducted normally.

For import VAT deferred declaration, the principal does not need to have import and export rights, but the agency shall submit the deferred application on behalf of the principal, and provide real sales contracts and domestic distribution certificates at the same time, to avoid tax inspection caused by inconsistent declaration entities. In addition, for small-batch cross-border e-commerce goods, they can be declared through the 9610 cross-border e-commerce mode, and enjoy simplified tax procedures without holding import and export rights.

**status:** suggested
**Author:** Linda Gao
**Date:** 2026-09-30

### Answer 5

From the perspective of cross-border receipt and payment compliance, when the principal of agency customs declaration does not have import and export rights, it needs to rely on the agency to complete foreign exchange receipt and payment operations. The principal shall sign a "foreign exchange receipt and payment agency agreement" with the agency in advance to clarify the transfer path and time limit of the payment for goods, so as to avoid settlement delay caused by inconsistency between capital flow and goods ownership flow.

If RMB cross-border payment (CIPS) is adopted, it is necessary to ensure that the agency has CIPS settlement qualification, and note "agent import payment" and the customs declaration form number in the remark column of the payment message, to avoid being listed as an abnormal transaction by the State Administration of Foreign Exchange. In addition, the principal shall keep all foreign exchange receipt and payment vouchers and agency agreements for at least 5 years for inspection by the State Administration of Foreign Exchange.

**status:** suggested
**Author:** Evelyn Li
**Date:** 2026-09-30

### Answer 6

From the perspective of international trade legal compliance, when the principal of agency customs declaration does not have import and export rights, it is necessary to focus on the terms and provisions of the agency agreement. The agreement must specify core contents such as the qualification scope of the agency, division of customs declaration responsibilities, and ownership of goods, so as to avoid legal disputes caused by illegal operations of the agency.

If the principal is penalized by customs due to lack of import and export rights, the compensation liability of the agency, including direct losses such as demurrage charges and fines, shall be stipulated in the agreement. In addition, the principal shall keep all communication records and documents with the agency, which can be used as legal evidence in case of disputes.

**status:** suggested
**Author:** Daniel Xu
**Date:** 2026-09-30

### Answer 7

From the perspective of on-site customs inspection, when the principal of agency customs declaration does not have import and export rights, it is necessary to prepare a full set of entrustment certification documents in advance, including the agency customs declaration agreement, the business license of the principal, and the goods list, so as to avoid inspection delay caused by lack of qualification documents during on-site inspection.

If the on-site customs raises questions about qualification, the agency shall issue a "import and export right qualification borrowing certificate" at the first time, and cooperate with customs inspection personnel to check the goods information and the contents of the customs declaration form. In addition, for sensitive goods (such as beauty products), product quality inspection reports and certificates of origin shall be prepared in advance, to avoid that the compliance problems of the goods themselves cover up the qualification problems, leading to more serious customs detention risks.

**status:** suggested
**Author:** Victor Sun
**Date:** 2026-09-30

### Answer 8

From the perspective of export tax rebate compliance, if the principal is an export enterprise without import and export rights, it shall ensure that the agency has the export tax rebate agency qualification when entrusting agency customs declaration, and note the words "entrusted export" on the customs declaration form at the same time.

The principal shall confirm the circulation process of tax rebate documents with the agency in advance to ensure the "consistency of four flows" including purchase contracts, customs declaration forms, and foreign exchange receipt vouchers, so as to avoid rejection of tax rebate applications due to inconsistent documents. In addition, the principal shall cooperate with the agency to complete the pre-declaration and formal declaration within the tax rebate declaration period (before the deadline of the VAT tax declaration period in April of the following year after the goods are declared for export), to avoid tax rebate losses caused by overdue declaration.

**status:** suggested
**Author:** Eric Zhou
**Date:** 2026-09-30

## 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/)
- [Customs Declaration Q&A](https://www.sh-zhongshen.com/en/qa/cat-customs-declaration/)
- [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/)
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