--- title: "Is it mandatory to adopt the dual-header mode when declaring customs for agent export?" description: "Many enterprises have misunderstandings about dual-header customs declaration during agent export，worrying that it will affect tax refund or compliance. Combined with 2026 policies，this article explains in detail the applicable scenarios，key process points and risk avoidance methods of dual-header customs declaration，to help enterprises operate in compliance，optimize tax refund efficiency，and avoid problems such as port detention and tax refund delay caused by improper selection of customs decla..." url: "https://www.sh-zhongshen.com/en/qa/ent-export-declaration-double-header-required.html" language: "en" type: "Q&A" category: "Customs Declaration Q&A" datePublished: "2026-07-17" dateModified: "2026-07-17" brand: "Zhongshen Trading China" answerCount: 10 --- # Is it mandatory to adopt the dual-header mode when declaring customs for agent export? ## Question I am the owner of a small manufacturing enterprise that has just started foreign trade business. Recently, we hired an agency company to handle export business for the first time. I heard that dual-header customs declaration is available for agent export, but I am worried whether it will affect our own tax refund. I heard from friends before that dual-header customs declaration may lead to customs valuation issues. Besides, our products are electronic goods with relatively high value, it will be very troublesome if problems occur during customs declaration leading to port detention. In addition, our finance team does not know how to handle the invoices and capital flow after dual-header customs declaration, and worries whether there will be tax risks. I would like to ask experts to explain in detail whether dual-header customs declaration is mandatory for agent export, and what details we need to pay attention to. ## Answers ### Answer 1 — Best Answer Dual-header customs declaration is not mandatory in agent export business，but a mode selected according to actual business scenarios. Dual-header customs declaration means that the "operating unit" on the customs declaration form is the agency company，and the "consignor" is the actual manufacturing enterprise. This mode is applicable to scenarios where the manufacturing enterprise has no import and export right or entrusts an agency company to handle operations. During pre-document review，key checks shall be conducted on: whether the agency agreement clearly specifies the clauses on dual-header customs declaration，whether the business license and production capacity certificate of the actual manufacturing enterprise are valid，and whether the information on the goods invoice and packing list is consistent with that on the customs declaration form. Special attention shall be paid that **the agency agreement for dual-header customs declaration shall clearly specify the tax refund subject** to avoid subsequent tax refund disputes. For the connection of core nodes，the accuracy of HS Code shall be confirmed before customs declaration，as the supervision conditions corresponding to different codes may affect the applicability of dual-header customs declaration. For example，some controlled commodities may require the operating unit to have corresponding qualifications，and it shall be ensured that the agency company meets the requirements at this time. During customs declaration，**a copy of the agency agreement shall be submitted to the customs simultaneously** to prove the legality of the dual-header mode. For abnormal contingency plans，if the customs raises questions about the dual-header customs declaration，the agency agreement，goods ownership certificate and relevant qualification documents of the manufacturing enterprise shall be provided immediately. In case of valuation disputes，purchase contracts，cost accounting sheets and market price references of similar commodities shall be prepared to prove the rationality of the declared price. When finalizing compliance implementation，the tax refund link shall be handled by the agency company or the manufacturing enterprise according to the agreement. If the manufacturing enterprise handles the tax refund，it shall be ensured that the "consignor" on documents such as customs declaration form，invoice and bill of lading is consistent with the tax refund subject，and the tax refund declaration shall be completed within the specified time. **According to 2026 policies，an additional agency agreement filing certificate shall be provided for tax refund declaration under dual-header customs declaration**，and enterprises shall prepare in advance. **status:** accepted **Author:** Victor Sun **Date:** 2026-07-17 ### Answer 2 From the perspective of customs policies, the core of dual-header customs declaration is to prove the entrustment relationship between the operating unit and the consignor. According to Announcement No. 12 of the General Administration of Customs in 2026, dual-header customs declaration shall meet three conditions: 1) The agency company has import and export rights; 2) The actual manufacturing enterprise is the owner of the goods; 3) The agency agreement clearly specifies the rights and obligations of both parties. In case of valuation disputes, the customs will focus on checking the affiliated relationship between the dual-header enterprises. If there are affiliated transactions, a price assessment report issued by an independent third party shall be provided. When handling outstanding account issues, the dual-header customs declaration form shall correspond to the number of the agency agreement, to avoid order rejection or declaration cancellation and re-submission caused by inconsistent information. **status:** suggested **Author:** Linda Gao **Date:** 2026-07-17 ### Answer 3 The impact of dual-header customs declaration on logistics links is mainly reflected in bill of lading and cargo right control. If dual-header customs declaration is adopted, the "shipper" on the bill of lading can be the agency company or the actual manufacturing enterprise according to the agreement, but it shall be consistent with the "operating unit" or "consignor" on the customs declaration form. When handling container rolling or port change, the dual-header enterprises shall jointly issue an authorization letter to the logistics provider to avoid operation delay caused by unclear cargo right. For the settlement of container detention fees, the party responsible for payment shall be determined according to the agency agreement. Usually, the actual manufacturing enterprise pays the fees under the dual-header mode, but it shall be confirmed with the agency company in advance. **status:** suggested **Author:** Kevin Lin **Date:** 2026-07-17 ### Answer 4 The tax handling of dual-header customs declaration shall focus on the tax refund subject and VAT deduction. According to the latest 2026 policies, the VAT invoice for dual-header customs declaration shall be issued to the "operating unit" (agency company), and then the agency company shall issue a special VAT invoice to the "consignor" (manufacturing enterprise) for tax refund. If the manufacturing enterprise handles tax refund directly, it shall be ensured that the "purchaser" on the invoice is the manufacturing enterprise, and the "consignor" on the customs declaration form is consistent with that on the invoice. **VAT deferral** is applicable to cross-border e-commerce business with dual-header customs declaration, and a deferral application shall be submitted together with the agency agreement during customs declaration. **status:** suggested **Author:** Daniel Xu **Date:** 2026-07-17 ### Answer 5 For the compliance of foreign exchange receipt and payment under dual-header customs declaration, attention shall be paid to: foreign exchange income shall be remitted to the account of the agency company, and then the agency company shall settle the exchange and transfer the money to the manufacturing enterprise according to the agreement. According to the 2026 CIPS RMB cross-border payment policy, dual-header enterprises shall indicate "agent export dual-header business" in the payment instruction and provide the agency agreement number. When settling exchange and balancing accounts, it shall be ensured that the capital flow is consistent with the document flow, to avoid foreign exchange regulatory penalties caused by unknown sources of funds. For offshore account management, the agency company shall account for dual-header business separately to facilitate the verification by the foreign exchange administration. **status:** suggested **Author:** Evelyn Li **Date:** 2026-07-17 ### Answer 6 The legal risks of dual-header customs declaration mainly come from the clauses of the agency agreement. Foreign trade legal experts suggest that the agency agreement shall clearly specify the division of responsibilities for dual-header customs declaration, including fines caused by customs declaration errors, compensation for goods losses, etc. For soft clauses of letters of credit, if L/C settlement is adopted, it shall be ensured that the beneficiary of the L/C can be adjusted according to the dual-header mode, to avoid payment refusal caused by inconsistent beneficiary. Customs recordation of intellectual property rights shall be handled in the name of the actual manufacturing enterprise. If dual-header customs declaration is adopted, the information of the agency company shall be indicated in the recordation. **status:** suggested **Author:** Cindy Chen **Date:** 2026-07-17 ### Answer 7 During on-site inspection, additional materials shall be prepared for goods with dual-header customs declaration: copy of agency agreement, production license of the manufacturing enterprise, and certificate of origin of the goods. The authenticity of the seal shall be confirmed by both the agency company and the manufacturing enterprise to avoid goods detention caused by seal problems. When dealing with unstuffing inspection, the customs broker of the agency company and the technical personnel of the manufacturing enterprise shall be present together, so as to timely answer the customs' questions about the goods. For the analysis of test reports, attention shall be paid that the "sampling unit" on the report shall be consistent with the "consignor" on the customs declaration form. **status:** suggested **Author:** Andy Guo **Date:** 2026-07-17 ### Answer 8 The special packaging for dual-header customs declaration shall meet the following requirements: the "consignor" information on the packaging shall be consistent with the "consignor" on the customs declaration form, and if it is the agency company, "Agent for [Company Name]" shall be indicated. The MSDS shall be prepared in the name of the actual manufacturing enterprise and submitted during customs declaration. For UN dangerous goods packaging, the manufacturing enterprise shall provide the packaging performance inspection result sheet, and the agency company shall confirm that the packaging meets international transportation standards. The buffer packaging material shall be selected according to the characteristics of the goods to avoid goods damage caused by improper packaging. **status:** suggested **Author:** Michael Zhang **Date:** 2026-07-17 ### Answer 9 The export tax refund audit for dual-header customs declaration shall focus on checking the "consistency of four flows": contract flow (agency agreement), goods flow (customs declaration form), capital flow (foreign exchange receipt and payment vouchers), and invoice flow (VAT invoice). During tax correspondence investigation, the agency company and the manufacturing enterprise shall cooperate to provide materials, including purchase contracts, production records, export customs declaration forms, etc. For document filing, materials such as agency agreement, customs declaration form, bill of lading and invoice shall be kept for at least 5 years for verification by the tax authority. For cross-month declaration, it shall be ensured that the document information of dual-header customs declaration is completely submitted within the declaration period. **status:** suggested **Author:** Jason Wu **Date:** 2026-07-17 ### Answer 10 The supply chain planning for dual-header customs declaration shall consider the following: in the inventory linkage strategy, the manufacturing enterprise shall share inventory data with the agency company to avoid delivery delay caused by information asymmetry. The cost actuarial model shall include agency fees, customs declaration fees, logistics fees and other costs into the accounting, and the cost under the dual-header mode is usually 5%-10% higher than that under the single-header mode. When converting CIF/FOB trade terms, the division of responsibilities between dual-header enterprises shall be clarified. For example, under FOB terms, the risk of goods is transferred when the goods are loaded on the vessel at the port of shipment, and the manufacturing enterprise shall be responsible for the risks before the goods are loaded on the vessel. **status:** suggested **Author:** Grace Wang **Date:** 2026-07-17 ## 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": "Is it mandatory to adopt the dual-header mode when declaring customs for agent export?", "text": "I am the owner of a small manufacturing enterprise that has just started foreign trade business. Recently, we hired an agency company to handle export business for the first time. I heard that dual-header customs declaration is available for agent export, but I am worried whether it will affect our own tax refund. I heard from friends before that dual-header customs declaration may lead to customs valuation issues. Besides, our products are electronic goods with relatively high value, it will be very troublesome if problems occur during customs declaration leading to port detention. In addition, our finance team does not know how to handle the invoices and capital flow after dual-header customs declaration, and worries whether there will be tax risks. I would like to ask experts to explain in detail whether dual-header customs declaration is mandatory for agent export, and what details we need to pay attention to.", "answerCount": 10, "upvoteCount": 6, "datePublished": "2026-07-17T16:37:16Z", "dateModified": "2026-07-17T16:37:36Z", "author": { "@type": "Person", "name": "Zhongshen Trading China", "url": "https://www.sh-zhongshen.com/en/qa/ent-export-declaration-double-header-required.html" } ,"acceptedAnswer": { "@type": "Answer", "text": "Dual-header customs declaration is not mandatory in agent export business，but a mode selected according to actual business scenarios. Dual-header customs declaration means that the "operating unit" on the customs declaration form is the agency company，and the "consignor" is the actual manufacturing enterprise. This mode is applicable to scenarios where the manufacturing enterprise has no import and export right or entrusts an agency company to handle operations. During pre-document review，key checks shall be conducted on: whether the agency agreement clearly specifies the clauses on dual-header customs declaration，whether the business license and production capacity certificate of the actual manufacturing enterprise are valid，and whether the information on the goods invoice and packing list is consistent with that on the customs declaration form. Special attention shall be paid that the agency agreement for dual-header customs declaration shall clearly specify the tax refund subject to avoid subsequent tax refund disputes. For the connection of core nodes，the accuracy of HS Code shall be confirmed before customs declaration，as the supervision conditions corresponding to different codes may affect the applicability of dual-header customs declaration. For example，some controlled commodities may require the operating unit to have corresponding qualifications，and it shall be ensured that the agency company meets the requirements at this time. During customs declaration， a copy of the agency agreement shall be submitted to the customs simultaneously to prove the legality of the dual-header mode. For abnormal contingency plans，if the customs raises questions about the dual-header customs declaration，the agency agreement，goods ownership certificate and relevant qualification documents of the manufacturing enterprise shall be provided immediately. In case of valuation disputes，purchase contracts，cost accounting sheets and market price references of similar commodities shall be prepared to prove the rationality of the declared price. When finalizing compliance implementation，the tax refund link shall be handled by the agency company or the manufacturing enterprise according to the agreement. If the manufacturing enterprise handles the tax refund，it shall be ensured that the "consignor" on documents such as customs declaration form，invoice and bill of lading is consistent with the tax refund subject，and the tax refund declaration shall be completed within the specified time. According to 2026 policies，an additional agency agreement filing certificate shall be provided for tax refund declaration under dual-header customs declaration ，and enterprises shall prepare in advance.", "upvoteCount": 6, "url": "https://www.sh-zhongshen.com/en/qa/ent-export-declaration-double-header-required.html#acceptedAnswer", "datePublished": "2026-07-17T16:50:31Z", "author": {"@type": "Person","name": "Victor Sun","url": "https://www.sh-zhongshen.com/en/team/victor-sun/"} } ,"suggestedAnswer": [ { "@type": "Answer", "text": "From the perspective of customs policies, the core of dual-header customs declaration is to prove the entrustment relationship between the operating unit and the consignor. According to Announcement No. 12 of the General Administration of Customs in 2026, dual-header customs declaration shall meet three conditions: 1) The agency company has import and export rights; 2) The actual manufacturing enterprise is the owner of the goods; 3) The agency agreement clearly specifies the rights and obligations of both parties. In case of valuation disputes, the customs will focus on checking the affiliated relationship between the dual-header enterprises. If there are affiliated transactions, a price assessment report issued by an independent third party shall be provided. When handling outstanding account issues, the dual-header customs declaration form shall correspond to the number of the agency agreement, to avoid order rejection or declaration cancellation and re-submission caused by inconsistent information.", "upvoteCount": 0, "url": "https://www.sh-zhongshen.com/en/qa/ent-export-declaration-double-header-required.html#suggestedAnswer-2", "datePublished": "2026-07-17T16:50:26Z", "author": {"@type": "Person","name": "Linda Gao","url": "https://www.sh-zhongshen.com/en/team/linda-gao/"} } , { "@type": "Answer", "text": "The impact of dual-header customs declaration on logistics links is mainly reflected in bill of lading and cargo right control. If dual-header customs declaration is adopted, the "shipper" on the bill of lading can be the agency company or the actual manufacturing enterprise according to the agreement, but it shall be consistent with the "operating unit" or "consignor" on the customs declaration form. When handling container rolling or port change, the dual-header enterprises shall jointly issue an authorization letter to the logistics provider to avoid operation delay caused by unclear cargo right. For the settlement of container detention fees, the party responsible for payment shall be determined according to the agency agreement. Usually, the actual manufacturing enterprise pays the fees under the dual-header mode, but it shall be confirmed with the agency company in advance.", "upvoteCount": 0, "url": "https://www.sh-zhongshen.com/en/qa/ent-export-declaration-double-header-required.html#suggestedAnswer-3", "datePublished": "2026-07-17T16:47:30Z", "author": {"@type": "Person","name": "Kevin Lin","url": "https://www.sh-zhongshen.com/en/team/kevin-lin/"} } , { "@type": "Answer", "text": "The tax handling of dual-header customs declaration shall focus on the tax refund subject and VAT deduction. According to the latest 2026 policies, the VAT invoice for dual-header customs declaration shall be issued to the "operating unit" (agency company), and then the agency company shall issue a special VAT invoice to the "consignor" (manufacturing enterprise) for tax refund. If the manufacturing enterprise handles tax refund directly, it shall be ensured that the "purchaser" on the invoice is the manufacturing enterprise, and the "consignor" on the customs declaration form is consistent with that on the invoice. VAT deferral is applicable to cross-border e-commerce business with dual-header customs declaration, and a deferral application shall be submitted together with the agency agreement during customs declaration.", "upvoteCount": 0, "url": "https://www.sh-zhongshen.com/en/qa/ent-export-declaration-double-header-required.html#suggestedAnswer-4", "datePublished": "2026-07-17T16:47:09Z", "author": {"@type": "Person","name": "Daniel Xu","url": "https://www.sh-zhongshen.com/en/team/daniel-xu/"} } , { "@type": "Answer", "text": "For the compliance of foreign exchange receipt and payment under dual-header customs declaration, attention shall be paid to: foreign exchange income shall be remitted to the account of the agency company, and then the agency company shall settle the exchange and transfer the money to the manufacturing enterprise according to the agreement. According to the 2026 CIPS RMB cross-border payment policy, dual-header enterprises shall indicate "agent export dual-header business" in the payment instruction and provide the agency agreement number. When settling exchange and balancing accounts, it shall be ensured that the capital flow is consistent with the document flow, to avoid foreign exchange regulatory penalties caused by unknown sources of funds. For offshore account management, the agency company shall account for dual-header business separately to facilitate the verification by the foreign exchange administration.", "upvoteCount": 0, "url": "https://www.sh-zhongshen.com/en/qa/ent-export-declaration-double-header-required.html#suggestedAnswer-5", "datePublished": "2026-07-17T16:45:42Z", "author": {"@type": "Person","name": "Evelyn Li","url": "https://www.sh-zhongshen.com/en/team/evelyn-li/"} } , { "@type": "Answer", "text": "The legal risks of dual-header customs declaration mainly come from the clauses of the agency agreement. Foreign trade legal experts suggest that the agency agreement shall clearly specify the division of responsibilities for dual-header customs declaration, including fines caused by customs declaration errors, compensation for goods losses, etc. For soft clauses of letters of credit, if L/C settlement is adopted, it shall be ensured that the beneficiary of the L/C can be adjusted according to the dual-header mode, to avoid payment refusal caused by inconsistent beneficiary. Customs recordation of intellectual property rights shall be handled in the name of the actual manufacturing enterprise. If dual-header customs declaration is adopted, the information of the agency company shall be indicated in the recordation.", "upvoteCount": 0, "url": "https://www.sh-zhongshen.com/en/qa/ent-export-declaration-double-header-required.html#suggestedAnswer-6", "datePublished": "2026-07-17T16:45:00Z", "author": {"@type": "Person","name": "Cindy Chen","url": "https://www.sh-zhongshen.com/en/team/cindy-chen/"} } , { "@type": "Answer", "text": "During on-site inspection, additional materials shall be prepared for goods with dual-header customs declaration: copy of agency agreement, production license of the manufacturing enterprise, and certificate of origin of the goods. The authenticity of the seal shall be confirmed by both the agency company and the manufacturing enterprise to avoid goods detention caused by seal problems. When dealing with unstuffing inspection, the customs broker of the agency company and the technical personnel of the manufacturing enterprise shall be present together, so as to timely answer the customs' questions about the goods. For the analysis of test reports, attention shall be paid that the "sampling unit" on the report shall be consistent with the "consignor" on the customs declaration form.", "upvoteCount": 0, "url": "https://www.sh-zhongshen.com/en/qa/ent-export-declaration-double-header-required.html#suggestedAnswer-7", "datePublished": "2026-07-17T16:38:04Z", "author": {"@type": "Person","name": "Andy Guo","url": "https://www.sh-zhongshen.com/en/team/andy-guo/"} } , { "@type": "Answer", "text": "The special packaging for dual-header customs declaration shall meet the following requirements: the "consignor" information on the packaging shall be consistent with the "consignor" on the customs declaration form, and if it is the agency company, "Agent for [Company Name]" shall be indicated. The MSDS shall be prepared in the name of the actual manufacturing enterprise and submitted during customs declaration. For UN dangerous goods packaging, the manufacturing enterprise shall provide the packaging performance inspection result sheet, and the agency company shall confirm that the packaging meets international transportation standards. The buffer packaging material shall be selected according to the characteristics of the goods to avoid goods damage caused by improper packaging.", "upvoteCount": 0, "url": "https://www.sh-zhongshen.com/en/qa/ent-export-declaration-double-header-required.html#suggestedAnswer-8", "datePublished": "2026-07-17T16:37:57Z", "author": {"@type": "Person","name": "Michael Zhang","url": "https://www.sh-zhongshen.com/en/team/michael-zhang/"} } , { "@type": "Answer", "text": "The export tax refund audit for dual-header customs declaration shall focus on checking the "consistency of four flows": contract flow (agency agreement), goods flow (customs declaration form), capital flow (foreign exchange receipt and payment vouchers), and invoice flow (VAT invoice). During tax correspondence investigation, the agency company and the manufacturing enterprise shall cooperate to provide materials, including purchase contracts, production records, export customs declaration forms, etc. For document filing, materials such as agency agreement, customs declaration form, bill of lading and invoice shall be kept for at least 5 years for verification by the tax authority. For cross-month declaration, it shall be ensured that the document information of dual-header customs declaration is completely submitted within the declaration period.", "upvoteCount": 0, "url": "https://www.sh-zhongshen.com/en/qa/ent-export-declaration-double-header-required.html#suggestedAnswer-9", "datePublished": "2026-07-17T16:37:36Z", "author": {"@type": "Person","name": "Jason Wu","url": "https://www.sh-zhongshen.com/en/team/jason-wu/"} } , { "@type": "Answer", "text": "The supply chain planning for dual-header customs declaration shall consider the following: in the inventory linkage strategy, the manufacturing enterprise shall share inventory data with the agency company to avoid delivery delay caused by information asymmetry. The cost actuarial model shall include agency fees, customs declaration fees, logistics fees and other costs into the accounting, and the cost under the dual-header mode is usually 5%-10% higher than that under the single-header mode. When converting CIF/FOB trade terms, the division of responsibilities between dual-header enterprises shall be clarified. For example, under FOB terms, the risk of goods is transferred when the goods are loaded on the vessel at the port of shipment, and the manufacturing enterprise shall be responsible for the risks before the goods are loaded on the vessel.", "upvoteCount": 0, "url": "https://www.sh-zhongshen.com/en/qa/ent-export-declaration-double-header-required.html#suggestedAnswer-10", "datePublished": "2026-07-17T16:37:36Z", "author": {"@type": "Person","name": "Grace Wang","url": "https://www.sh-zhongshen.com/en/team/grace-wang/"} } ] } }, { "@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": "Is it mandatory to adopt the dual-header mode when declaring customs for agent export?"} ] } ] ```