---
title: "In Export Agency Business, Whose Name Should Be Used for Customs Declaration?"
description: "When factories without self-operated import and export right entrust foreign trade agencies for export，they often get anxious about the selection of customs declaration entity，worrying that wrong selection will affect order delivery，tax refund and compliance records. It is necessary to clarify the qualification matching principle first: entities without import and export right can only declare in the name of the agent，while entities with relevant qualification can choose according to trade terms..."
url: "https://www.sh-zhongshen.com/en/qa/export-agent-customs-declaration-entity.html"
language: "en"
type: "Q&A"
category: "Customs Declaration Q&A"
datePublished: "2026-09-26"
dateModified: "2026-09-26"
brand: "Zhongshen Trading China"
answerCount: 9
---

# In Export Agency Business, Whose Name Should Be Used for Customs Declaration?

## Question

 I am the head of a smart home factory located in Qingpu District, Shanghai. I just secured an annual order of 3 million euros from a German client. Since our factory does not have self-operated import and export right, we signed an export agency agreement with Zhongshen last week. Yesterday, our cooperating forwarder suddenly asked me whose name should be used for customs declaration, and I got flustered immediately. I heard from a neighboring factory that declaring in the agent's name brings faster customs clearance, but last week I saw an industry news that a factory was audited by tax authorities during export tax refund for declaring in the agent's name, which was marked as inconsistency of the four flows; some people said we can declare in the factory's own name, but we don't have import and export right at all! Now there are only 10 days left before container loading. If I choose wrong, not only will the goods be detained at the port generating hundreds of thousands of port detention fees, but it may also affect subsequent tax refund and our cooperation with the German client. I am really anxious now and just want to figure out whose name should I use for customs declaration, and what risks must be avoided in advance? 

## Answers
                            
### Answer 1 — Best Answer

First，we need to clarify common misunderstandings in the industry: many small and medium-sized factories choose customs declaration entity randomly，either default to the agent's name for convenience，or forcefully declare in their own name ignoring qualification restrictions.

If you fall into these misunderstandings，it will trigger a series of negative consequences: for example，if a factory without import and export right forcefully declares in its own name，the declaration will be directly rejected by customs. If the goods are detained at the port for more than 72 hours，it will incur port detention fees and container detention fees，and the factory may even be listed on the customs key supervision list，if you declare in the agent's name but do not clarify rights and responsibilities in advance，and cargo detention occurs later due to wrong data on the customs declaration，the factory may bear full responsibility due to vague agreement terms，and its credit rating with credit insurance companies will also be affected.

Risk isolation measures: Check your own qualification first. Factories without import and export right must declare customs in the name of the agent，entities with import and export right can choose according to trade terms，**it is recommended to use the agent's name under FOB terms**，to leverage the agent's Class A customs credit rating to reduce inspection rate.

Practical loss mitigation tips: When signing an agency agreement，you must clearly define the division of rights and responsibilities of the customs declaration entity，and retain all documents including customs power of attorney，trade contract，invoices and other documents for at least 5 years，at the same time，you should require the agent to synchronize customs declaration progress. If any abnormality occurs，the contingency plan shall be activated within 24 hours，and the agent shall take the lead in coordinating with customs to solve the problem.

**status:** accepted
**Author:** Jason Wu
**Date:** 2026-09-26

### Answer 2

The selection of customs declaration entity must comply with the Administrative Measures for Customs Declaration of Import and Export Goods newly revised by the General Administration of Customs of China in 2026. Domestic enterprises without import and export operation right must entrust qualified foreign trade agency enterprises to declare customs in the agent's name; enterprises with import and export operation right can choose to declare in their own name or the agent's name, but must ensure the consistency of the declaration entity with the trade contract and bill of lading consignee.

If you choose to declare in the agent's name, you need to submit the Customs Brokerage Power of Attorney sealed with both parties' official seals to customs, fill in the agent's name and customs code in the "business unit" column of the customs declaration form, and fill in the actual consignee information in the "consignee" column. If the data on the customs declaration form does not match the actual goods, the agent shall bear the primary declaration responsibility, but the principal shall cooperate with customs to complete the verification.

**status:** suggested
**Author:** Andy Guo
**Date:** 2026-09-26

### Answer 3

The selection of customs declaration entity directly affects cargo title transfer and logistics cost. If declaring in the agent's name, the bill of lading consignee must be consistent with the agent's name, and the agent needs to endorse and transfer it to the overseas client later. The cargo title transfer must be clearly stipulated in the agency agreement to avoid the risk of "agent detaining cargo"; if declaring in the principal's name, the bill of lading can be directly consigned to the overseas client, making cargo title transfer more straightforward, but it must be confirmed that the principal has import and export right, otherwise the forwarder cannot book shipping space.

In addition, the "Smart Customs Clearance" system implemented by Shanghai Port in 2026 gives priority review to customs declaration forms from Class A credit enterprises. If the agent is a Class A enterprise, choosing to declare in the agent's name can shorten customs clearance time by more than 20% and reduce the risk of cargo detention at the port.

**status:** suggested
**Author:** Linda Gao
**Date:** 2026-09-26

### Answer 4

The selection of customs declaration entity has a significant impact on export tax refund and VAT deferral. If declaring in the agent's name, export tax refund shall be declared uniformly by the agent, and the principal needs to provide all input invoices and export documents to ensure the consistency of "contract flow, capital flow, invoice flow and cargo flow".

The State Taxation Administration requires that agency tax refund declaration must upload the electronically signed version of the agency agreement in 2026; if declaring in the principal's name, tax refund shall be declared by the principal itself, but the principal must have import and export right and tax refund qualification. For orders from the European market, declaring in the agent's name allows application for EU VAT deferral, which eliminates the need to pay import VAT in the importing country and directly reduces capital occupation cost by about 15%.

**status:** suggested
**Author:** Lucas Liu
**Date:** 2026-09-26

### Answer 5

The selection of customs declaration entity must match the foreign exchange receipt and payment path. If declaring in the agent's name, the foreign exchange receipt must first enter the agent's foreign exchange account, and the agent will transfer it to the principal's account after settlement. It is necessary to confirm that the agent's foreign exchange account has the qualification for current account foreign exchange receipt and payment.

The People's Bank of China requires that agency foreign exchange receipt and payment must upload the electronic data of the agency agreement and customs declaration form in 2026; if declaring in the principal's name, foreign exchange receipt can directly enter the principal's foreign exchange account, but the principal must complete the procedures for import and export right and open a foreign exchange settlement account. In addition, if choosing to declare in the agent's name, the method of locking the settlement exchange rate must be clearly defined in the agency agreement to avoid exchange rate loss.

**status:** suggested
**Author:** Michael Zhang
**Date:** 2026-09-26

### Answer 6

The selection of customs declaration entity and division of rights and responsibilities must be clearly agreed in the agency agreement to avoid subsequent legal disputes. If declaring in the agent's name, the agreement must clearly define the agent's declaration obligations, including document review, data entry, abnormality handling, etc. If declaration error occurs due to the agent's mistake, the agent shall be liable for compensation of port detention fees, customs detention losses and export tax refund failure; if declaring in the principal's name, the agreement must clearly stipulate that the principal needs to provide true and valid documents.

If compliance risk occurs due to false documents provided by the principal, the principal shall bear full responsibility. In addition, the storage method of customs declaration documents must be stipulated in the agreement to ensure compliance with the file management requirements of customs and tax authorities.

**status:** suggested
**Author:** Eric Zhou
**Date:** 2026-09-26

### Answer 7

There are differences in inspection probability and response procedures for different customs declaration entities. If declaring in the agent's name and the agent is a Class A credit enterprise certified by customs, the inspection rate is only 0.5%. If inspection is required, the agent's on-site specialist can directly coordinate with customs, and the principal does not need to be present; if declaring in the principal's name and the principal declares for the first time, the inspection rate is as high as 10%, and the principal needs to be present to cooperate with the unpacking inspection.

If the principal cannot be present, a power of attorney must be provided. The "Machine Inspection First" policy implemented by Shanghai Customs in 2026 arranges priority machine inspection for customs declaration forms from Class A enterprises, which can shorten the inspection time to less than 4 hours.

**status:** suggested
**Author:** Kevin Lin
**Date:** 2026-09-26

### Answer 8

The selection of customs declaration entity directly affects the compliance of export tax refund. If declaring in the agent's name, it is necessary to ensure that the agent's export tax refund qualification is valid, and the tax refund data declared by the agent is completely consistent with the customs declaration form, input invoice and foreign exchange receipt voucher. The "Golden Tax Phase IV" system of tax authorities will automatically compare the four flow data in 2026.

If there is any discrepancy, it will directly trigger tax correspondence investigation and affect the tax refund progress; if declaring in the principal's name, it is necessary to ensure that the principal's tax refund filing information is consistent with the information on the customs declaration form. If the principal is a newly established enterprise, it must complete tax refund filing before customs declaration, otherwise it cannot declare tax refund. In addition, no matter which declaration entity you choose, you must retain all documents for at least 5 years for tax audit.

**status:** suggested
**Author:** Cindy Chen
**Date:** 2026-09-26

### Answer 9

From the perspective of long-term supply chain planning, the selection of customs declaration entity must match the enterprise's development strategy. If an enterprise plans to build its own brand and expand the international market, it is recommended to gradually transition to declaring in its own name, accumulate its own customs credit rating, and enjoy policy benefits such as customs clearance convenience and priority tax refund in the future; if an enterprise focuses on production and has no plan to expand its foreign trade team, it is recommended to declare in the agent's name for a long term, and leverage the agent's professional capabilities to reduce compliance risks.

The "Credit Linkage" policy implemented by customs in 2026 stipulates that an enterprise's customs credit rating will affect its convenience measures in logistics, taxation and other aspects, so it is necessary to select a suitable customs declaration entity according to the enterprise's development stage.

**status:** suggested
**Author:** Victor Sun
**Date:** 2026-09-26

## 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/)

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- [Trade Cases](https://www.sh-zhongshen.com/en/cases/)
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