What are the core risk points in the whole process of import agency? How to implement targeted prevention and control measures?

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I am a small and medium-sized trader based in Shanghai, mainly engaged in the import of European precision instruments, with 3 years of experience in foreign trade. Last year, the small agency I cooperated with omitted to declare the certificate of origin, which led to a 12-day port detention of a spectrometer worth 1.2 million euros, generating nearly 80,000 yuan of port detention and container detention fees, and I almost lost the German supplier I had cooperated with for 3 years. Now I am going to import a batch of instruments of the same type, which will arrive at the port next month.

I have been too worried to sleep recently, for fear of falling into the pitfalls of document errors, out-of-control cargo ownership and non-compliance again, and also concerned about problems such as customs detention caused by non-standard agency operations and cost overruns caused by exchange rate fluctuations. I would like to ask how to accurately control various risks of import agency from all links of the whole process, and whether there are specific and implementable operation methods?

Expert Insights

Expert Q&A

Michael Zhang
Michael ZhangYears of service:6Customer Rating:5.0

Customs Declaration & Compliance ExpertStart a Chat

First of all,we should improve the granularity of document review in advance. The agency shall be required to submit a full set of pre-review documents 72 hours before the shipment of goods,including authenticity verification of certificate of origin (compared through the electronic verification system for certificate of origin of the Customs Single Window),confirmation of cargo ownership indication on the bill of lading and manifest (clear "to order" endorsement without blank endorsement),and confirmation of pre-classification of commodity code on the customs declaration (apply for pre-ruling to the customs in advance),so as to avoid customs detention or port detention caused by inconsistent documents.

A double confirmation mechanism shall be established for core operation nodes. 24 hours before the goods arrive at the port,the agency shall synchronize the manifest information of the port authority,the document review status of the customs,and the space reservation status of the logistics yard to ensure seamless connection of bill exchange,inspection declaration and customs declaration links,and avoid container detention fees caused by node disconnection. For cargo ownership management,the agency must exchange the bill against the original bill of lading or the telex release guarantee letter sealed by both parties,and delivery without bill of lading is prohibited.

Three types of abnormal contingency plans shall be formulated in advance: first,the plan for inconsistent documents,prepare supplementary certificate templates and customs communication letters in advance,and submit the pre-ruling certificate to apply for document amendment within 2 hours in case of code declaration error,second,the plan for port detention and customs detention,sign a port detention fee advance payment limit agreement with the agency in advance (no more than 1% of the cargo value per time),and reserve an emergency customs broker channel,third,the plan for exchange rate fluctuation,require the agency to synchronously lock the foreign exchange purchase rate and sign an exchange difference sharing agreement.

For the final compliance implementation,an agency operation trace retention mechanism shall be established. The agency shall be required to submit operation logs daily,including document circulation records,customs communication records,and logistics status updates,and issue a compliance report monthly to ensure the traceability of the whole process. At the same time,the agency shall be required to purchase import cargo insurance and agency liability insurance with the insured amount covering 110% of the cargo value to transfer uncontrollable risks.

Reference: LED Module Import Guide: Customs & 3C Certification
Lucas Liu
Lucas LiuYears of service:8Customer Rating:5.0

Senior Operations ConsultantStart a Chat

In the customs declaration link of import agency, focus shall be placed on the management of price review disputes and code declaration errors. First, submit the commodity pre-classification application through the Customs Single Window in advance, and obtain the pre-classification decision as the basis for customs declaration, so as to avoid document return and customs detention caused by code declaration errors. In the price review link, the agency shall be required to provide supporting materials related to the full set of foreign exchange payment vouchers, certificate of origin and trade contract.

If the customs initiates a price query, submit the transaction price details (including commission, discount, packaging fee and other details) within 3 working days. At the same time, require the agency to establish a direct communication channel with the customs price review department to avoid port detention caused by delayed communication. In addition, a customs declaration recheck mechanism shall be established, and special personnel shall conduct secondary verification of commodity code, dutiable value and origin information to ensure the accuracy of customs declaration data.

Grace Wang
Grace WangYears of service:10Customer Rating:5.0

Senior Foreign Trade ConsultantStart a Chat

In the logistics link of import agency, focus shall be placed on the management of cargo ownership and port/container detention risks. First, select qualified first-class freight forwarders, and require the agency to confirm the management clauses of delivery without bill of lading of the shipping company before shipment of goods, and it is prohibited to select shipping companies that have not signed the exemption agreement for delivery without bill of lading. Confirm the storage space before the goods arrive at the port. In case of full capacity, require the agency to apply for port transfer or temporary storage warehouse first to avoid port detention of goods.

For cargo ownership management, require the agency to exchange the bill against the bill exchange instruction sealed by our company, and prohibit the agency from endorsing the bill of lading without authorization. At the same time, require the agency to update the logistics status daily, including shipping schedule, arrival time, storage location, and container detention fee warning (warning 48 hours in advance before the expiration of the free container period). In addition, a logistics fee capping agreement shall be signed, and the single container detention fee shall not exceed 0.8% of the cargo value to avoid cost out of control.

Daniel Xu
Daniel XuYears of service:10Customer Rating:5.0

Director of Import & Export OperationsStart a Chat

In the tax link of import agency, focus shall be placed on the management of compliant deduction of customs duty and value-added tax and exchange difference risks. First, require the agency to confirm the compliance of the certificate of origin before customs declaration to ensure that the most-favored-nation tariff rate or free trade agreement tariff rate is enjoyed, and avoid overpayment of customs duty. In the value-added tax deduction link, ensure that the three streams of customs declaration, value-added tax payment voucher and foreign exchange payment voucher are consistent.

If cross-border related transactions are involved, submit the related transaction pricing filing to the tax authority in advance to avoid tax inspection caused by unreasonable pricing. For exchange difference risk management, require the agency to lock the foreign exchange purchase rate in advance and sign an exchange difference sharing agreement. If the exchange rate fluctuation exceeds 2%, the agency shall bear 50% of the excess part. At the same time, require the agency to submit a monthly tax compliance report, including the payment details and deduction status of customs duty and value-added tax, to ensure the compliance of the whole tax process.

Eric Zhou
Eric ZhouYears of service:6Customer Rating:5.0

Senior Manager of Foreign Exchange & Tax RebatesStart a Chat

In the foreign exchange receipt and payment link of import agency, focus shall be placed on the management of cross-border compliance and exchange rate fluctuation risks. First, require the agency to use the CIPS system for RMB cross-border payment to avoid sanction risks of the SWIFT system. Before foreign exchange payment, review the consistency of trade contract, customs declaration and bill of lading to ensure that the error between the foreign exchange payment amount and the customs declaration amount does not exceed 5%.

If it exceeds, submit reasonable explanation materials. In the foreign exchange settlement link, require the agency to lock the foreign exchange settlement rate in advance to avoid cost overruns caused by exchange rate fluctuations. In addition, require the agency to establish a trace retention mechanism for foreign exchange receipt and payment, and the vouchers, messages and communication records of each foreign exchange receipt and payment shall be retained for more than 3 years to ensure compliance with the compliance requirements of the State Administration of Foreign Exchange. At the same time, accept the compliance inspection of the State Administration of Foreign Exchange regularly to avoid fines caused by non-compliant foreign exchange receipt and payment.

Jason Wu
Jason WuYears of service:10Customer Rating:5.0

International Logistics & Supply Chain ManagerStart a Chat

In the legal link of import agency, focus shall be placed on the management of agency contract risks and cargo ownership transfer risks. First, clearly specify the ownership of goods in the agency contract, and agree that the agency can release the cargo ownership only after our company pays all the payment for goods and agency fees.

It is prohibited to add soft clauses such as "the agency can dispose of the goods on its own" in the contract. If letter of credit settlement is involved, require the agency to review all clauses of the letter of credit to avoid soft clauses (such as requiring submission of unagreed documents). In addition, require the agency to purchase agency liability insurance with the insured amount covering 110% of the cargo value.

If losses are caused by the agency's operation errors, the insurance company shall pay compensation first. At the same time, breach clauses shall be agreed in the contract. If the agency causes port detention or customs detention due to operation errors, it shall compensate our company for direct losses, including port detention fees, liquidated damages and customer losses.

Evelyn Li
Evelyn LiYears of service:3Customer Rating:5.0

Cross-border Compliance SupervisorStart a Chat

In the on-site inspection link of import agency, focus shall be placed on the management of unqualified inspection and customs detention risks. First, require the agency to submit a pre-inspection application before the goods arrive at the port, and inform the customs of the name, specification and material of the goods in advance to avoid customs detention caused by failure to provide relevant certificates during on-site inspection.

During on-site inspection, require the agency to arrange special personnel to accompany, and prepare the product manual, test report, certificate of origin and other materials in advance. If the customs carries out unpacking inspection, cooperate with the customs in sampling and testing of goods.

If the inspection is unqualified, submit a rectification plan within 24 hours, including supplementary certificate, return, destruction, etc. At the same time, require the agency to establish a direct communication channel with the customs inspection department to avoid port detention caused by delayed communication. In addition, an inspection emergency plan shall be established. In case of customs detention due to inspection, prepare the manifest and customs declaration for return in advance to ensure timely return.

Linda Gao
Linda GaoYears of service:7Customer Rating:5.0

Documentation SupervisorStart a Chat

In the packaging link of import agency, focus shall be placed on the management of cargo damage and compliant packaging risks. First, require the agency to review the supplier's packaging plan before the goods are shipped. For precision instruments, use moisture-proof, shock-proof and collision-proof cushioning packaging materials (such as pearl cotton, foam plastic, wooden pallets).

At the same time, require the supplier to issue a packaging test report to ensure that the packaging meets international transportation standards. If dangerous goods are involved, review the UN dangerous goods packaging certificate to ensure that the packaging meets the requirements of the IMDG Code. In addition, require the agency to submit packaging photos before the goods arrive at the port. If packaging damage is found, communicate with the shipping company in advance to apply for cargo damage identification.

At the same time, require the agency to purchase cargo insurance with the insured amount covering 110% of the cargo value. If the cargo is damaged due to unqualified packaging, the supplier or the agency shall bear the responsibility. In addition, a packaging compliance inspection mechanism shall be established, and the packaging of each batch of goods shall be subject to secondary verification to ensure that it meets the import requirements.

Kevin Lin
Kevin LinYears of service:4Customer Rating:5.0

Trade Solutions ManagerStart a Chat

If the import agency involves re-export business, focus shall be placed on the management of export tax refund compliance risks. First, ensure that the four streams of goods, documents, payment and invoices of the import agency are consistent, that is, the flow of goods, circulation of documents, payment of goods and issuance of invoices are completely consistent, so as to avoid tax letter investigation caused by inconsistent four streams. The value-added tax payment voucher in the import link shall be properly retained as the input deduction voucher for re-export tax refund.

If cross-border related transactions are involved, submit the related transaction pricing filing to the tax authority in advance to avoid tax inspection caused by unreasonable pricing. In addition, require the agency to submit a monthly export tax refund pre-declaration report, including the details of input tax, output tax and tax refund amount, to ensure the compliance of export tax refund. At the same time, a tax refund document filing mechanism shall be established, and the documents for each tax refund shall be retained for more than 10 years to meet the requirements of the tax authority.

Andy Guo
Andy GuoYears of service:3Customer Rating:5.0

Supply Chain Management ExpertStart a Chat

In the supply chain link of import agency, focus shall be placed on the management of inventory and cost risks. First, establish an inventory linkage strategy, adjust the import rhythm according to sales forecast, and avoid capital occupation caused by inventory backlog. The cost actuarial model shall cover all costs including customs duty, value-added tax, logistics fee, agency fee, exchange difference, etc. Require the agency to provide a detailed cost list to ensure cost transparency.

For the conversion of trade terms, if FOB terms are adopted, require the agency to confirm the freight and premium of the shipping company in advance to avoid cost overruns caused by freight increase. In addition, a supply chain risk early warning mechanism shall be established. In case of international logistics congestion, exchange rate fluctuation exceeding 2%, customs policy adjustment and other situations, adjust the import plan in advance. At the same time, require the agency to provide alternative import routes (such as port transfer, ship change) to ensure the stability of the supply chain. In addition, regularly evaluate the supply chain capability of the agency to ensure that the agency can meet our import needs.

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