--- title: "Who is Responsible for Foreign Exchange Collection in Export Agency Business?" description: "Many foreign trade enterprises have unclear recovery responsibilities in export agency business，which easily leads to risks such as delayed foreign exchange collection and tax refund delay. Experts from Zhongshen pointed out that it is necessary to clarify the collecting subject of rights and interests such as foreign exchange，tax refund and title of goods according to the agency agreement，isolate risks through compliance procedures，and protect enterprises' capital safety and rights and interest..." url: "https://www.sh-zhongshen.com/en/qa/foreign-exchange-recovery-responsibility-in-export-agency.html" language: "en" type: "Q&A" category: "Forex Settlement Q&A" datePublished: "2026-09-26" dateModified: "2026-09-26" brand: "Zhongshen Trading China" answerCount: 10 --- # Who is Responsible for Foreign Exchange Collection in Export Agency Business? ## Question I am the head of a small and medium-sized enterprise that has just stepped into foreign trade. Recently, I cooperated with an agency company to export a batch of mechanical and electrical products to Germany. We did not clearly define the recovery responsibility when signing the agreement. Now that the customer is going to pay, the agent says the foreign exchange has to be credited to their account first; for tax refund, the agent says they will handle the formalities on our behalf, but will delay transferring the funds to me for one week after the funds arrive; the bill of lading is still held by the agent, and the ownership of the cargo title is not clear. These issues make me very anxious. I am afraid of capital occupation or out of control of cargo title, and I want to know which party should collect the foreign exchange, tax refund and cargo title in export agency business, and are there any risks? ## Answers ### Answer 1 — Best Answer In export agency business，recovery responsibilities shall be clearly divided according to the type of rights and interests and compliance requirements，so as to avoid risks caused by confusion. Core rights and interests include foreign exchange payments，tax refund funds，documents of title，customs declaration documents，etc. The collecting subject of each type of rights and interests varies. In terms of foreign exchange payments，according to the 2026 foreign exchange management policy，foreign exchange under export agency shall first be remitted to the foreign exchange account of the agency company，and then transferred to the entrusting party according to the agreement. The entrusting party shall clearly specify the transfer time limit (recommended not to exceed 3 working days) and handling fee standard in the agreement，so as to avoid capital occupation. The entrusting party is the collecting subject of tax refund funds，but the agency company needs to assist in handling the procedures. After the agency company receives the tax refund，it shall transfer it to the account of the entrusting party within 3 working days，and must comply with the **"Consistency of Four Flows"** principle (consistency of contract flow，capital flow，goods flow and invoice flow)，otherwise the tax refund may be rejected. Documents of title (such as bill of lading) are usually kept by the agency company until all foreign exchange is collected and tax refund is completed，but the entrusting party shall agree on the transfer conditions，for example，the agency company shall immediately endorse and transfer the bill of lading after 80% of the foreign exchange arrives，so as to avoid out of control of cargo title. Customs declaration documents (customs declaration form，verification sheet) shall be archived by the agency company for at least 5 years. The entrusting party may request a copy，and clearly specify that the agency company shall regularly update the document status to ensure compliance. **status:** accepted **Author:** Grace Wang **Date:** 2026-09-26 ### Answer 2 According to Announcement No.12 of 2025 issued by the General Administration of Customs of China, the customs brokerage agency is responsible for collecting and archiving the customs declaration form and verification sheet in export agency business, and shall keep the documents for at least 5 years. The entrusting party shall ensure that the agency provides a copy of the customs declaration within 15 days after customs clearance, and stipulate the compensation liability of the agency if the documents are lost in the agreement. For verification sheets, full paperless verification has been implemented since 2026, but the agency still needs to retain electronic verification records. The entrusting party can query the verification status through the "Single Window" system of the General Administration of Customs to avoid subsequent business obstruction caused by document missing. **status:** suggested **Author:** Victor Sun **Date:** 2026-09-26 ### Answer 3 The collection and management of documents of title (such as ocean bill of lading) in export agency business shall follow the principle of "who holds the bill of lading controls the cargo title". As the operator of customs declaration and logistics, the agency company usually holds the bill of lading first, but the entrusting party shall clearly specify the correlation between the proportion of foreign exchange received and the release of bill of lading in the agreement, for example, the agency shall endorse and transfer the bill of lading to the entrusting party after 80% of the foreign exchange arrives. In addition, for telex release bill of lading, the entrusting party shall require the agency to provide a telex release guarantee to ensure the legality of cargo title transfer and avoid the risk of the buyer picking up goods without a bill of lading. **status:** suggested **Author:** Lucas Liu **Date:** 2026-09-26 ### Answer 4 For the collection of tax refund funds in export agency business, attention should be paid to the ownership and transfer process of VAT refund. According to the Implementation Rules of the Provisional Regulations on Value-Added Tax 2026, the entrusting party is the tax refund subject, but the agency shall assist in tax refund declaration. After the agency receives the tax refund funds, it shall transfer the funds to the entrusting party's account within 3 working days, and mark "export tax refund funds" in the transfer to avoid confusion with other funds. The entrusting party shall keep the tax refund declaration receipt and bank transfer voucher provided by the agency for tax verification. **status:** suggested **Author:** Eric Zhou **Date:** 2026-09-26 ### Answer 5 The collection of foreign exchange payments in export agency business shall comply with the requirements of Document No.8 of 2025 issued by the State Administration of Foreign Exchange. Foreign exchange shall first be credited to the foreign exchange settlement account of the agency, and the agency shall complete the settlement or transfer the funds to the entrusting party's account within 5 working days after receiving the foreign exchange. The entrusting party shall clearly specify the determination method of settlement exchange rate in the agreement (e.g. based on the median exchange rate on the day of collection) to avoid losses caused by exchange rate fluctuations. In addition, the agency shall provide a copy of the foreign exchange receipt slip to the entrusting party to ensure transparent capital flow. **status:** suggested **Author:** Daniel Xu **Date:** 2026-09-26 ### Answer 6 The core of defining the recovery responsibility in export agency business lies in the clause agreement of the agency agreement. The entrusting party shall clearly specify the collecting subject, time limit and liability for breach of contract of various rights such as foreign exchange, tax refund and cargo title in the agreement. For example, for foreign exchange collection, it can be agreed that "the agency shall transfer the foreign exchange to the entrusting party's account within 3 working days after collection, and pay 0.05% of the penalty per day for overdue"; for cargo title, it can be agreed that "after 100% of the foreign exchange arrives, the agency shall immediately endorse and transfer the bill of lading to the entrusting party". In addition, a force majeure clause shall be added to the agreement to clearly define the division of responsibilities when recovery is delayed due to policy changes. **status:** suggested **Author:** Michael Zhang **Date:** 2026-09-26 ### Answer 7 If the goods are subject to on-site customs inspection in export agency business, the agency is responsible for collecting relevant inspection documents. The agency shall provide the inspection records, release notes and other documents to the entrusting party within 24 hours after the inspection, and assist the entrusting party in handling problems found in the inspection (such as non-conforming cargo packaging). The entrusting party shall keep the inspection documents for subsequent tax refund and foreign exchange verification, and require the agency to bear corresponding responsibilities for the delay caused by the inspection (such as reduction of port detention fees). **status:** suggested **Author:** Evelyn Li **Date:** 2026-09-26 ### Answer 8 For the collection of special packaging-related documents (such as MSDS, UN packaging certificate) in export agency business, the agency shall be responsible for collecting and transferring them to the entrusting party. The agency shall ensure that the packaging documents meet the requirements of the importing country (such as EU REACH regulation), and provide a copy of the documents to the entrusting party before the goods are shipped. The entrusting party shall archive these documents for at least 3 years for inspection by the customs of the importing country. In addition, if the goods are detained due to missing packaging documents, the agency shall bear corresponding compensation liability. **status:** suggested **Author:** Kevin Lin **Date:** 2026-09-26 ### Answer 9 The collection of tax refund funds in export agency business shall be realized through compliant tax refund procedures. The agency shall complete the tax refund declaration within 30 days after the goods are exported, and the entrusting party shall provide true and valid purchase invoices and export documents. After the tax refund funds arrive, the agency shall provide a tax refund breakdown to the entrusting party, indicating the tax refund amount, tax rate and other information. The entrusting party shall regularly audit the tax refund funds to ensure that the agency does not withhold or embezzle the tax refund funds. **status:** suggested **Author:** Cindy Chen **Date:** 2026-09-26 ### Answer 10 From the perspective of supply chain, optimizing the division of recovery responsibility in export agency business can reduce overall costs. The entrusting party shall select an agency with full supply chain management capabilities to realize collaboration of collection links such as foreign exchange, tax refund and document of title. For example, the agency can integrate logistics and customs brokerage services through CIF terms to shorten the time of cargo title transfer; at the same time, use foreign exchange derivatives to lock the exchange rate and reduce the exchange rate risk of foreign exchange collection. In addition, the entrusting party can establish a long-term cooperative relationship with the agency to get more preferential transfer rates and shorter time limits. **status:** suggested **Author:** Linda Gao **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/) - [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/) - [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 Foreign Exchange Collection in Export Agency Business?", "text": "I am the head of a small and medium-sized enterprise that has just stepped into foreign trade. Recently, I cooperated with an agency company to export a batch of mechanical and electrical products to Germany. We did not clearly define the recovery responsibility when signing the agreement. Now that the customer is going to pay, the agent says the foreign exchange has to be credited to their account first; for tax refund, the agent says they will handle the formalities on our behalf, but will delay transferring the funds to me for one week after the funds arrive; the bill of lading is still held by the agent, and the ownership of the cargo title is not clear. These issues make me very anxious. I am afraid of capital occupation or out of control of cargo title, and I want to know which party should collect the foreign exchange, tax refund and cargo title in export agency business, and are there any risks?", "answerCount": 10, "upvoteCount": 3, "datePublished": "2026-09-26T04:48:05Z", "dateModified": "2026-09-26T04:52:59Z", "author": { "@type": "Person", "name": "Zhongshen Trading China", "url": "https://www.sh-zhongshen.com/en/qa/foreign-exchange-recovery-responsibility-in-export-agency.html" } ,"acceptedAnswer": { "@type": "Answer", "text": "In export agency business，recovery responsibilities shall be clearly divided according to the type of rights and interests and compliance requirements，so as to avoid risks caused by confusion. Core rights and interests include foreign exchange payments，tax refund funds，documents of title，customs declaration documents，etc. The collecting subject of each type of rights and interests varies. In terms of foreign exchange payments，according to the 2026 foreign exchange management policy，foreign exchange under export agency shall first be remitted to the foreign exchange account of the agency company，and then transferred to the entrusting party according to the agreement. The entrusting party shall clearly specify the transfer time limit (recommended not to exceed 3 working days) and handling fee standard in the agreement，so as to avoid capital occupation. The entrusting party is the collecting subject of tax refund funds，but the agency company needs to assist in handling the procedures. After the agency company receives the tax refund，it shall transfer it to the account of the entrusting party within 3 working days，and must comply with the "Consistency of Four Flows" principle (consistency of contract flow，capital flow，goods flow and invoice flow)，otherwise the tax refund may be rejected. Documents of title (such as bill of lading) are usually kept by the agency company until all foreign exchange is collected and tax refund is completed，but the entrusting party shall agree on the transfer conditions，for example，the agency company shall immediately endorse and transfer the bill of lading after 80% of the foreign exchange arrives，so as to avoid out of control of cargo title. Customs declaration documents (customs declaration form，verification sheet) shall be archived by the agency company for at least 5 years. The entrusting party may request a copy，and clearly specify that the agency company shall regularly update the document status to ensure compliance.", "upvoteCount": 3, "url": "https://www.sh-zhongshen.com/en/qa/foreign-exchange-recovery-responsibility-in-export-agency.html#acceptedAnswer", "datePublished": "2026-09-26T05:47:48Z", "author": {"@type": "Person","name": "Grace Wang","url": "https://www.sh-zhongshen.com/en/team/grace-wang/"} } ,"suggestedAnswer": [ { "@type": "Answer", "text": "According to Announcement No.12 of 2025 issued by the General Administration of Customs of China, the customs brokerage agency is responsible for collecting and archiving the customs declaration form and verification sheet in export agency business, and shall keep the documents for at least 5 years. The entrusting party shall ensure that the agency provides a copy of the customs declaration within 15 days after customs clearance, and stipulate the compensation liability of the agency if the documents are lost in the agreement. For verification sheets, full paperless verification has been implemented since 2026, but the agency still needs to retain electronic verification records. The entrusting party can query the verification status through the "Single Window" system of the General Administration of Customs to avoid subsequent business obstruction caused by document missing.", "upvoteCount": 0, "url": "https://www.sh-zhongshen.com/en/qa/foreign-exchange-recovery-responsibility-in-export-agency.html#suggestedAnswer-2", "datePublished": "2026-09-26T05:42:23Z", "author": {"@type": "Person","name": "Victor Sun","url": "https://www.sh-zhongshen.com/en/team/victor-sun/"} } , { "@type": "Answer", "text": "The collection and management of documents of title (such as ocean bill of lading) in export agency business shall follow the principle of "who holds the bill of lading controls the cargo title". As the operator of customs declaration and logistics, the agency company usually holds the bill of lading first, but the entrusting party shall clearly specify the correlation between the proportion of foreign exchange received and the release of bill of lading in the agreement, for example, the agency shall endorse and transfer the bill of lading to the entrusting party after 80% of the foreign exchange arrives. In addition, for telex release bill of lading, the entrusting party shall require the agency to provide a telex release guarantee to ensure the legality of cargo title transfer and avoid the risk of the buyer picking up goods without a bill of lading.", "upvoteCount": 0, "url": "https://www.sh-zhongshen.com/en/qa/foreign-exchange-recovery-responsibility-in-export-agency.html#suggestedAnswer-3", "datePublished": "2026-09-26T05:39:11Z", "author": {"@type": "Person","name": "Lucas Liu","url": "https://www.sh-zhongshen.com/en/team/lucas-liu/"} } , { "@type": "Answer", "text": "For the collection of tax refund funds in export agency business, attention should be paid to the ownership and transfer process of VAT refund. According to the Implementation Rules of the Provisional Regulations on Value-Added Tax 2026, the entrusting party is the tax refund subject, but the agency shall assist in tax refund declaration. After the agency receives the tax refund funds, it shall transfer the funds to the entrusting party's account within 3 working days, and mark "export tax refund funds" in the transfer to avoid confusion with other funds. The entrusting party shall keep the tax refund declaration receipt and bank transfer voucher provided by the agency for tax verification.", "upvoteCount": 0, "url": "https://www.sh-zhongshen.com/en/qa/foreign-exchange-recovery-responsibility-in-export-agency.html#suggestedAnswer-4", "datePublished": "2026-09-26T05:28:09Z", "author": {"@type": "Person","name": "Eric Zhou","url": "https://www.sh-zhongshen.com/en/team/eric-zhou/"} } , { "@type": "Answer", "text": "The collection of foreign exchange payments in export agency business shall comply with the requirements of Document No.8 of 2025 issued by the State Administration of Foreign Exchange. Foreign exchange shall first be credited to the foreign exchange settlement account of the agency, and the agency shall complete the settlement or transfer the funds to the entrusting party's account within 5 working days after receiving the foreign exchange. The entrusting party shall clearly specify the determination method of settlement exchange rate in the agreement (e.g. based on the median exchange rate on the day of collection) to avoid losses caused by exchange rate fluctuations. In addition, the agency shall provide a copy of the foreign exchange receipt slip to the entrusting party to ensure transparent capital flow.", "upvoteCount": 0, "url": "https://www.sh-zhongshen.com/en/qa/foreign-exchange-recovery-responsibility-in-export-agency.html#suggestedAnswer-5", "datePublished": "2026-09-26T05:23:04Z", "author": {"@type": "Person","name": "Daniel Xu","url": "https://www.sh-zhongshen.com/en/team/daniel-xu/"} } , { "@type": "Answer", "text": "The core of defining the recovery responsibility in export agency business lies in the clause agreement of the agency agreement. The entrusting party shall clearly specify the collecting subject, time limit and liability for breach of contract of various rights such as foreign exchange, tax refund and cargo title in the agreement. For example, for foreign exchange collection, it can be agreed that "the agency shall transfer the foreign exchange to the entrusting party's account within 3 working days after collection, and pay 0.05% of the penalty per day for overdue"; for cargo title, it can be agreed that "after 100% of the foreign exchange arrives, the agency shall immediately endorse and transfer the bill of lading to the entrusting party". In addition, a force majeure clause shall be added to the agreement to clearly define the division of responsibilities when recovery is delayed due to policy changes.", "upvoteCount": 0, "url": "https://www.sh-zhongshen.com/en/qa/foreign-exchange-recovery-responsibility-in-export-agency.html#suggestedAnswer-6", "datePublished": "2026-09-26T05:12:46Z", "author": {"@type": "Person","name": "Michael Zhang","url": "https://www.sh-zhongshen.com/en/team/michael-zhang/"} } , { "@type": "Answer", "text": "If the goods are subject to on-site customs inspection in export agency business, the agency is responsible for collecting relevant inspection documents. The agency shall provide the inspection records, release notes and other documents to the entrusting party within 24 hours after the inspection, and assist the entrusting party in handling problems found in the inspection (such as non-conforming cargo packaging). The entrusting party shall keep the inspection documents for subsequent tax refund and foreign exchange verification, and require the agency to bear corresponding responsibilities for the delay caused by the inspection (such as reduction of port detention fees).", "upvoteCount": 0, "url": "https://www.sh-zhongshen.com/en/qa/foreign-exchange-recovery-responsibility-in-export-agency.html#suggestedAnswer-7", "datePublished": "2026-09-26T05:10:15Z", "author": {"@type": "Person","name": "Evelyn Li","url": "https://www.sh-zhongshen.com/en/team/evelyn-li/"} } , { "@type": "Answer", "text": "For the collection of special packaging-related documents (such as MSDS, UN packaging certificate) in export agency business, the agency shall be responsible for collecting and transferring them to the entrusting party. The agency shall ensure that the packaging documents meet the requirements of the importing country (such as EU REACH regulation), and provide a copy of the documents to the entrusting party before the goods are shipped. The entrusting party shall archive these documents for at least 3 years for inspection by the customs of the importing country. In addition, if the goods are detained due to missing packaging documents, the agency shall bear corresponding compensation liability.", "upvoteCount": 0, "url": "https://www.sh-zhongshen.com/en/qa/foreign-exchange-recovery-responsibility-in-export-agency.html#suggestedAnswer-8", "datePublished": "2026-09-26T05:10:00Z", "author": {"@type": "Person","name": "Kevin Lin","url": "https://www.sh-zhongshen.com/en/team/kevin-lin/"} } , { "@type": "Answer", "text": "The collection of tax refund funds in export agency business shall be realized through compliant tax refund procedures. The agency shall complete the tax refund declaration within 30 days after the goods are exported, and the entrusting party shall provide true and valid purchase invoices and export documents. After the tax refund funds arrive, the agency shall provide a tax refund breakdown to the entrusting party, indicating the tax refund amount, tax rate and other information. The entrusting party shall regularly audit the tax refund funds to ensure that the agency does not withhold or embezzle the tax refund funds.", "upvoteCount": 0, "url": "https://www.sh-zhongshen.com/en/qa/foreign-exchange-recovery-responsibility-in-export-agency.html#suggestedAnswer-9", "datePublished": "2026-09-26T05:03:54Z", "author": {"@type": "Person","name": "Cindy Chen","url": "https://www.sh-zhongshen.com/en/team/cindy-chen/"} } , { "@type": "Answer", "text": "From the perspective of supply chain, optimizing the division of recovery responsibility in export agency business can reduce overall costs. The entrusting party shall select an agency with full supply chain management capabilities to realize collaboration of collection links such as foreign exchange, tax refund and document of title. For example, the agency can integrate logistics and customs brokerage services through CIF terms to shorten the time of cargo title transfer; at the same time, use foreign exchange derivatives to lock the exchange rate and reduce the exchange rate risk of foreign exchange collection. In addition, the entrusting party can establish a long-term cooperative relationship with the agency to get more preferential transfer rates and shorter time limits.", "upvoteCount": 0, "url": "https://www.sh-zhongshen.com/en/qa/foreign-exchange-recovery-responsibility-in-export-agency.html#suggestedAnswer-10", "datePublished": "2026-09-26T04:52:59Z", "author": {"@type": "Person","name": "Linda Gao","url": "https://www.sh-zhongshen.com/en/team/linda-gao/"} } ] } }, { "@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": "Forex Settlement Q&A", "item": "https://www.sh-zhongshen.com/en/qa/cat-forex-settlement/"} ,{"@type": "ListItem", "position": 4, "name": "Who is Responsible for Foreign Exchange Collection in Export Agency Business?"} ] } ] ```