---
title: "Do all foreign trade companies have the legal qualification to act as export agents?"
description: "A small machinery manufacturing enterprise without import and export rights receives its first overseas order and intends to hire a foreign trade company as its export agent，but worries that unqualified agents will lead to cargo detention or tax refund failure. It should be clarified that not all foreign trade companies are eligible for legal export agency services. Enterprises shall verify core qualifications such as the agent's import and export operation rights，sign detailed agreements and ke..."
url: "https://www.sh-zhongshen.com/en/qa/do-all-foreign-trade-companies-have-legal-export-agency-qualification.html"
language: "en"
type: "Q&A"
category: "Export Agency Q&A"
datePublished: "2026-07-19"
dateModified: "2026-07-19"
brand: "Zhongshen Trading China"
answerCount: 8
---

# Do all foreign trade companies have the legal qualification to act as export agents?

## Question

 I am the owner of a newly established small machinery manufacturing enterprise. Last week, we finally received our first overseas order from Southeast Asia. Although the order value is not large, it is a critical step for us to enter the international market. However, our company does not have import and export rights yet, so we have to find a foreign trade company to act as our export agent. Recently, I heard from peers that some foreign trade companies do not have complete agency qualifications, and using their services may cause problems, such as cargo being detained at the port and unable to be retrieved, or stuck in the tax refund process resulting in failure to receive the refund. I am very anxious now. After all, this is our first order. If something goes wrong, it will not only cause financial losses, but also damage customer trust. I would like to ask if all foreign trade companies can legally act as export agents? What specific qualification certificates do I need to check before cooperation to avoid pitfalls? 

## Answers
                            
### Answer 1 — Best Answer

Not all foreign trade companies have the legal qualification to act as export agents，which is a common cognitive misunderstanding in the industry. Many small foreign trade companies may only hold a business license，but lack the key import and export operation permit. Entrusting such companies for export agency will directly lead to out-of-control follow-up processes.

If you choose an unqualified foreign trade company as your agent，you will first encounter obstacles in the customs declaration process: the customs system will reject the declaration because the agent company does not have a **Customs Declaration Unit Registration Certificate**，and the demurrage and storage fees incurred daily after the cargo is detained at the port will accumulate rapidly. If you forcefully declare through informal channels，the cargo may be identified as suspected of smuggling，facing seizure or even fines，which directly affects order delivery. In addition，unqualified companies cannot handle export tax refund filing，and the enterprise's tax refund application will be rejected by the tax authority，resulting in a loss of about 13% of the VAT refund.

The core measure for physical risk isolation is to verify three key qualifications: first，check the agent's **Import and Export Operation Right Filing Certificate** (which can be queried through the unified platform of the Ministry of Commerce's business system)，second，confirm that it holds a valid Customs Declaration Unit Registration Certificate，third，request the provision of an agency bookkeeping permit (if tax refund services are involved).

Exclusive loss-stopping tips: When signing the agency agreement，it is necessary to clearly stipulate that "if the cargo is detained or the tax refund fails due to the qualification problem of the agency company，the agency shall bear all losses"，keep copies of documents (such as customs declaration forms，bills of lading，invoices) for each step of the process，before formal customs declaration，require the agency company to conduct **pre-declaration verification** to ensure that all materials meet the requirements of customs and tax authorities，and eliminate risks in advance.

**status:** accepted
**Author:** Evelyn Li
**Date:** 2026-07-19

### Answer 2

From the perspective of customs declaration compliance, export agency services require the foreign trade company to hold a valid Customs Declaration Unit Registration Certificate, and its filing status on the General Administration of Customs "Internet + Customs" platform is "normal". If the agent company does not have this certificate, the customs declaration form will be automatically rejected by the system, resulting in cargo detention at the port.

In addition, the "trade mode" column of the export agency customs declaration form should be marked as "export agency", and the "remarks" column should fill in the name of the entrusting party and its unified social credit code, otherwise it will affect the subsequent tax refund. It is recommended to check the filing status of the agent company through the official website of the General Administration of Customs before cooperation to confirm that its customs declaration authority is valid.。

**status:** suggested
**Author:** Grace Wang
**Date:** 2026-07-19

### Answer 3

The control of cargo ownership for export agency needs to focus on the bill of lading endorsement link. If the agent company endorses and transfers the bill of lading without the explicit authorization of the entrusting party, it may lead to the loss of cargo ownership.

In addition, when choosing an agent company, it is necessary to confirm the stability of its cooperation with shipping companies, to avoid container rolling or space shortage caused by the credit problem of the agent company. For machinery cargo, the agent company should be able to provide packaging solutions that meet the requirements (such as rust prevention, shock prevention), and confirm the free storage period policy of the destination port in advance to avoid additional container detention fees.。

**status:** suggested
**Author:** Daniel Xu
**Date:** 2026-07-19

### Answer 4

In 2026, export agency tax refund needs to meet the "four streams consistency": contract stream, cargo stream, capital stream, and invoice stream are completely matched. If the capital return path of the agent company is not standardized (such as receiving foreign exchange through personal accounts), it will trigger tax letter investigation, resulting in delayed tax refund.

In addition, the agent company must have completed the export tax (exemption) refund filing, and the filing category is "foreign trade comprehensive service enterprise" or "other foreign trade enterprises". It is recommended to require the agent company to provide successful tax refund cases in the last 3 months to confirm that its tax refund process is compliant.。

**status:** suggested
**Author:** Victor Sun
**Date:** 2026-07-19

### Answer 5

The foreign exchange receipt and payment for export agency requires the agent company to be a Class A enterprise in the Foreign Exchange Receipt and Payment Directory. Such enterprises can enjoy simplified foreign exchange receipt and payment processes. If the agent company is a Class B/C enterprise, more supporting documents are required when receiving foreign exchange, which may lead to delayed fund arrival.

In addition, when conducting RMB cross-border payment through the CIPS system, the agent company needs to complete the enterprise information filing in the system to ensure that the payment instruction can pass smoothly. It is recommended to specify the foreign exchange receipt time (such as within 7 working days after the cargo departs from the port) and the calculation method of the settlement exchange rate in the agreement to avoid exchange difference losses.。

**status:** suggested
**Author:** Cindy Chen
**Date:** 2026-07-19

### Answer 6

A written agency agreement must be signed for export agency, clarifying the agency scope (such as customs declaration, logistics, tax refund), fee settlement standard (such as agency fee charged at 1%-3% of the order amount) and liability for breach of contract.

A "cargo ownership retention clause" should be added to the agreement, that is, before the entrusting party receives all the payment for goods, the agent company shall not transfer the cargo ownership without authorization. For orders settled by letter of credit, the agent company shall be required to provide letter of credit review services to avoid soft clause traps (such as "the bill of lading must be signed by the person designated by the buyer").。

**status:** suggested
**Author:** Eric Zhou
**Date:** 2026-07-19

### Answer 7

If the export agency cargo is inspected by the customs, the agent company shall have professional personnel present to cooperate. Complete documents (contract, invoice, packing list, MSDS) shall be provided during inspection. If the agent company cannot provide them in time, the inspection time will be extended.

In addition, the agent company should be able to identify the authenticity of seals: formal agents will use lead seals recognized by the customs to avoid the cargo being identified as tampered due to damaged seals. It is recommended to ask the agent company about cases of handling inspection abnormalities before cooperation to confirm its on-site response capability.。

**status:** suggested
**Author:** Michael Zhang
**Date:** 2026-07-19

### Answer 8

Export agency tax refund needs to ensure "four streams consistency": the information of contract, cargo, capital and invoice is completely matched. The agent company shall establish a perfect document filing system, store all materials (such as customs declaration forms, bills of lading, foreign exchange receipt vouchers) in a special warehouse, and the filing period shall meet the 2026 tax requirements (within 5 years from the date of export).

If the document management of the agent company is chaotic, it will lead to the failure of tax letter investigation and inability to obtain tax refund. It is recommended to require the agent company to provide a document filing list to check whether it meets the specifications.。

**status:** suggested
**Author:** Lucas Liu
**Date:** 2026-07-19

## Related Categories
- [Import Agency Q&A](https://www.sh-zhongshen.com/en/qa/cat-import-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/)
- [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": "Do all foreign trade companies have the legal qualification to act as export agents?",
        "text": "I am the owner of a newly established small machinery manufacturing enterprise. Last week, we finally received our first overseas order from Southeast Asia. Although the order value is not large, it is a critical step for us to enter the international market. However, our company does not have import and export rights yet, so we have to find a foreign trade company to act as our export agent. Recently, I heard from peers that some foreign trade companies do not have complete agency qualifications, and using their services may cause problems, such as cargo being detained at the port and unable to be retrieved, or stuck in the tax refund process resulting in failure to receive the refund. I am very anxious now. After all, this is our first order. If something goes wrong, it will not only cause financial losses, but also damage customer trust. I would like to ask if all foreign trade companies can legally act as export agents? What specific qualification certificates do I need to check before cooperation to avoid pitfalls?",
        "answerCount": 8,
        "upvoteCount": 2,
        "datePublished": "2026-07-19T16:09:12Z",
        "dateModified": "2026-07-19T16:16:37Z",
        "author": {
          "@type": "Person",
          "name": "Zhongshen Trading China",
          "url": "https://www.sh-zhongshen.com/en/qa/do-all-foreign-trade-companies-have-legal-export-agency-qualification.html"
        }
                ,"acceptedAnswer": {
            "@type": "Answer",
            "text": "Not all foreign trade companies have the legal qualification to act as export agents，which is a common cognitive misunderstanding in the industry. Many small foreign trade companies may only hold a business license，but lack the key import and export operation permit. Entrusting such companies for export agency will directly lead to out-of-control follow-up processes. If you choose an unqualified foreign trade company as your agent，you will first encounter obstacles in the customs declaration process: the customs system will reject the declaration because the agent company does not have a Customs Declaration Unit Registration Certificate ，and the demurrage and storage fees incurred daily after the cargo is detained at the port will accumulate rapidly. If you forcefully declare through informal channels，the cargo may be identified as suspected of smuggling，facing seizure or even fines，which directly affects order delivery. In addition，unqualified companies cannot handle export tax refund filing，and the enterprise's tax refund application will be rejected by the tax authority，resulting in a loss of about 13% of the VAT refund. The core measure for physical risk isolation is to verify three key qualifications: first，check the agent's Import and Export Operation Right Filing Certificate (which can be queried through the unified platform of the Ministry of Commerce's business system)，second，confirm that it holds a valid Customs Declaration Unit Registration Certificate，third，request the provision of an agency bookkeeping permit (if tax refund services are involved). Exclusive loss-stopping tips: When signing the agency agreement，it is necessary to clearly stipulate that "if the cargo is detained or the tax refund fails due to the qualification problem of the agency company，the agency shall bear all losses"，keep copies of documents (such as customs declaration forms，bills of lading，invoices) for each step of the process，before formal customs declaration，require the agency company to conduct pre-declaration verification to ensure that all materials meet the requirements of customs and tax authorities，and eliminate risks in advance.",
            "upvoteCount": 2,
            "url": "https://www.sh-zhongshen.com/en/qa/do-all-foreign-trade-companies-have-legal-export-agency-qualification.html#acceptedAnswer",
            "datePublished": "2026-07-19T17:37:48Z",
            "author": {"@type": "Person","name": "Evelyn Li","url": "https://www.sh-zhongshen.com/en/team/evelyn-li/"}        }
                ,"suggestedAnswer": [
                  {
            "@type": "Answer",
            "text": "From the perspective of customs declaration compliance, export agency services require the foreign trade company to hold a valid Customs Declaration Unit Registration Certificate, and its filing status on the General Administration of Customs "Internet + Customs" platform is "normal". If the agent company does not have this certificate, the customs declaration form will be automatically rejected by the system, resulting in cargo detention at the port. In addition, the "trade mode" column of the export agency customs declaration form should be marked as "export agency", and the "remarks" column should fill in the name of the entrusting party and its unified social credit code, otherwise it will affect the subsequent tax refund. It is recommended to check the filing status of the agent company through the official website of the General Administration of Customs before cooperation to confirm that its customs declaration authority is valid.。",
            "upvoteCount": 0,
            "url": "https://www.sh-zhongshen.com/en/qa/do-all-foreign-trade-companies-have-legal-export-agency-qualification.html#suggestedAnswer-2",
            "datePublished": "2026-07-19T17:36:41Z",
            "author": {"@type": "Person","name": "Grace Wang","url": "https://www.sh-zhongshen.com/en/team/grace-wang/"}          }
          ,          {
            "@type": "Answer",
            "text": "The control of cargo ownership for export agency needs to focus on the bill of lading endorsement link. If the agent company endorses and transfers the bill of lading without the explicit authorization of the entrusting party, it may lead to the loss of cargo ownership. In addition, when choosing an agent company, it is necessary to confirm the stability of its cooperation with shipping companies, to avoid container rolling or space shortage caused by the credit problem of the agent company. For machinery cargo, the agent company should be able to provide packaging solutions that meet the requirements (such as rust prevention, shock prevention), and confirm the free storage period policy of the destination port in advance to avoid additional container detention fees.。",
            "upvoteCount": 0,
            "url": "https://www.sh-zhongshen.com/en/qa/do-all-foreign-trade-companies-have-legal-export-agency-qualification.html#suggestedAnswer-3",
            "datePublished": "2026-07-19T17:34:07Z",
            "author": {"@type": "Person","name": "Daniel Xu","url": "https://www.sh-zhongshen.com/en/team/daniel-xu/"}          }
          ,          {
            "@type": "Answer",
            "text": "In 2026, export agency tax refund needs to meet the "four streams consistency": contract stream, cargo stream, capital stream, and invoice stream are completely matched. If the capital return path of the agent company is not standardized (such as receiving foreign exchange through personal accounts), it will trigger tax letter investigation, resulting in delayed tax refund. In addition, the agent company must have completed the export tax (exemption) refund filing, and the filing category is "foreign trade comprehensive service enterprise" or "other foreign trade enterprises". It is recommended to require the agent company to provide successful tax refund cases in the last 3 months to confirm that its tax refund process is compliant.。",
            "upvoteCount": 0,
            "url": "https://www.sh-zhongshen.com/en/qa/do-all-foreign-trade-companies-have-legal-export-agency-qualification.html#suggestedAnswer-4",
            "datePublished": "2026-07-19T17:28:15Z",
            "author": {"@type": "Person","name": "Victor Sun","url": "https://www.sh-zhongshen.com/en/team/victor-sun/"}          }
          ,          {
            "@type": "Answer",
            "text": "The foreign exchange receipt and payment for export agency requires the agent company to be a Class A enterprise in the Foreign Exchange Receipt and Payment Directory. Such enterprises can enjoy simplified foreign exchange receipt and payment processes. If the agent company is a Class B/C enterprise, more supporting documents are required when receiving foreign exchange, which may lead to delayed fund arrival. In addition, when conducting RMB cross-border payment through the CIPS system, the agent company needs to complete the enterprise information filing in the system to ensure that the payment instruction can pass smoothly. It is recommended to specify the foreign exchange receipt time (such as within 7 working days after the cargo departs from the port) and the calculation method of the settlement exchange rate in the agreement to avoid exchange difference losses.。",
            "upvoteCount": 0,
            "url": "https://www.sh-zhongshen.com/en/qa/do-all-foreign-trade-companies-have-legal-export-agency-qualification.html#suggestedAnswer-5",
            "datePublished": "2026-07-19T17:15:40Z",
            "author": {"@type": "Person","name": "Cindy Chen","url": "https://www.sh-zhongshen.com/en/team/cindy-chen/"}          }
          ,          {
            "@type": "Answer",
            "text": "A written agency agreement must be signed for export agency, clarifying the agency scope (such as customs declaration, logistics, tax refund), fee settlement standard (such as agency fee charged at 1%-3% of the order amount) and liability for breach of contract. A "cargo ownership retention clause" should be added to the agreement, that is, before the entrusting party receives all the payment for goods, the agent company shall not transfer the cargo ownership without authorization. For orders settled by letter of credit, the agent company shall be required to provide letter of credit review services to avoid soft clause traps (such as "the bill of lading must be signed by the person designated by the buyer").。",
            "upvoteCount": 0,
            "url": "https://www.sh-zhongshen.com/en/qa/do-all-foreign-trade-companies-have-legal-export-agency-qualification.html#suggestedAnswer-6",
            "datePublished": "2026-07-19T17:11:28Z",
            "author": {"@type": "Person","name": "Eric Zhou","url": "https://www.sh-zhongshen.com/en/team/eric-zhou/"}          }
          ,          {
            "@type": "Answer",
            "text": "If the export agency cargo is inspected by the customs, the agent company shall have professional personnel present to cooperate. Complete documents (contract, invoice, packing list, MSDS) shall be provided during inspection. If the agent company cannot provide them in time, the inspection time will be extended. In addition, the agent company should be able to identify the authenticity of seals: formal agents will use lead seals recognized by the customs to avoid the cargo being identified as tampered due to damaged seals. It is recommended to ask the agent company about cases of handling inspection abnormalities before cooperation to confirm its on-site response capability.。",
            "upvoteCount": 0,
            "url": "https://www.sh-zhongshen.com/en/qa/do-all-foreign-trade-companies-have-legal-export-agency-qualification.html#suggestedAnswer-7",
            "datePublished": "2026-07-19T16:59:10Z",
            "author": {"@type": "Person","name": "Michael Zhang","url": "https://www.sh-zhongshen.com/en/team/michael-zhang/"}          }
          ,          {
            "@type": "Answer",
            "text": "Export agency tax refund needs to ensure "four streams consistency": the information of contract, cargo, capital and invoice is completely matched. The agent company shall establish a perfect document filing system, store all materials (such as customs declaration forms, bills of lading, foreign exchange receipt vouchers) in a special warehouse, and the filing period shall meet the 2026 tax requirements (within 5 years from the date of export). If the document management of the agent company is chaotic, it will lead to the failure of tax letter investigation and inability to obtain tax refund. It is recommended to require the agent company to provide a document filing list to check whether it meets the specifications.。",
            "upvoteCount": 0,
            "url": "https://www.sh-zhongshen.com/en/qa/do-all-foreign-trade-companies-have-legal-export-agency-qualification.html#suggestedAnswer-8",
            "datePublished": "2026-07-19T16:16:37Z",
            "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": "Export Agency Q&A", "item": "https://www.sh-zhongshen.com/en/qa/cat-export-agency/"}          ,{"@type": "ListItem", "position": 4, "name": "Do all foreign trade companies have the legal qualification to act as export agents?"}
      ]
    }
]
```