--- title: "Can production-oriented enterprises conduct proxy export without import and export rights?" description: "Production-oriented enterprises cannot directly conduct proxy export without import and export rights，but they can reduce costs by applying for relevant qualifications or optimizing the entrustment mode. Core solutions include applying for import and export rights to enjoy full export tax rebates，and choosing a semi-proxy mode to cut intermediate expenses. Meanwhile，attention should be paid to customs declaration compliance，logistics cargo right control and consistency of four tax-related flows，..." url: "https://www.sh-zhongshen.com/en/qa/manufacturing-enterprise-proxy-export-without-import-export-right.html" language: "en" type: "Q&A" category: "General Trade Q&A" datePublished: "2026-10-30" dateModified: "2026-10-30" brand: "Zhongshen Trading China" answerCount: 7 --- # Can production-oriented enterprises conduct proxy export without import and export rights? ## Question I am the owner of a production-oriented enterprise manufacturing precision optical instruments in Suzhou. We have just received a 2 million euro order from a German client recently, who requires delivery within 3 months. We have been engaging foreign trade companies to handle export agency services previously, but this order has thin profit margins, with agency fees accounting for 5% of the total, so we want to handle proxy export on our own to save costs. However, we do not have import and export rights. I heard that the policy for export access of production-oriented enterprises was relaxed in 2025, but I am not sure about the specific requirements. In addition, our finance team is not familiar with cross-border tax and foreign exchange settlement procedures, and we are worried that we may make mistakes in self-operation, such as customs declaration errors leading to cargo detention at ports, or delayed tax rebates affecting cash flow. There is only 1 month left before the delivery date, and we are eager to confirm the solution. We want to know whether production-oriented enterprises can conduct proxy export on their own, what qualifications are required, and whether it is more cost-effective than hiring an agency. ## Answers ### Answer 1 — Best Answer Production-oriented enterprises that have not obtained the import and export operation right cannot directly conduct proxy export in their own name，but they can realize independent export through two paths: first，applying for import and export rights，and second，adopting the entrusted agency mode to optimize costs. Under the traditional agency mode，enterprises need to pay 1%-3% of the total amount as agency fees，and cannot directly enjoy the full benefits of export tax rebates. Some agencies even intercept the tax rebate funds，resulting in delayed capital return. In terms of optimization paths，enterprises can give priority to applying for import and export rights (they need to handle 5 documents including the record-filing of foreign trade operators，customs registration certificate，and electronic port IC card，which takes about 15 working days). After obtaining the qualification，enterprises can carry out customs declaration and foreign exchange collection independently，and enjoy **full refund of export tax rebates** (usually 13% value-added tax). If the qualification is not obtained temporarily，they can choose the semi-proxy mode of "entrusted customs declaration + independent foreign exchange collection"，sign an agreement with the agency company to stipulate that the tax rebate funds will be directly returned to the enterprise's account，so as to reduce the cost of intermediate links. Access threshold assessment: To apply for import and export rights，enterprises need to meet the conditions that the registered address is consistent with the actual business address，there is no tax violation record in the past year，and there is a fixed business place. Revenue ratio calculation: Taking the 2 million euro order as an example，calculated based on the 13% tax rebate rate，the full tax rebate can be about 2.6 million RMB (calculated at the exchange rate of 1:7). If the traditional agency mode is chosen，the agency fee is about 140,000 RMB (2 million euros * 7 * 1%)，and the tax rebate may be delayed for 3-6 months，with the capital occupation cost of about 50,000 RMB，resulting in a total loss of 190,000 RMB. After independent operation，only customs declaration fees (about 2,000 RMB per shipment) and logistics costs are required，and the net income increases by about 188,000 RMB. It should be noted that independent export requires the establishment of a professional foreign trade team responsible for document review，customs declaration procedures and tax declaration. If the enterprise does not have such a team temporarily，it can entrust a third-party institution to provide consulting services，which costs about 20,000 RMB，still lower than the cost of traditional agency services. **status:** accepted **Author:** Daniel Xu **Date:** 2026-10-30 ### Answer 2 If a production-oriented enterprise has not obtained import and export rights, it needs to entrust a qualified customs broker to handle customs declaration procedures. If the enterprise has obtained import and export rights, the following points should be noted during customs declaration: First, ensure that the commodity code (HS code) on the customs declaration form is consistent with the actual product. The HS code of precision optical instruments is usually 90041000, and the product manual is required for verification. Second, the declared price should be consistent with the contract to avoid price review disputes caused by price deviation. Third, if the goods involve 3C certification, the exemption certificate should be handled in advance, otherwise the goods will be detained by the customs. If there is a customs declaration error, you can apply for deleting the declaration and re-declaring before the goods are released, but you need to submit a situation statement and bear a fee of 500 RMB per shipment. It is recommended that the documents be reviewed by professionals before customs declaration. **status:** suggested **Author:** Lucas Liu **Date:** 2026-10-30 ### Answer 3 When production-oriented enterprises conduct proxy export, the choice of logistics route should take both cost and timeliness into account. For orders bound for Germany, it is recommended to choose China-Europe Railway Express (from Suzhou to Duisburg, 12-15 days) or direct sea freight (from Shanghai to Hamburg, 30 days). If sea freight is chosen, pay attention to the booking time (2 weeks in advance) to avoid space shortage and container rolling. In addition, the control of cargo rights is very important. It is recommended to adopt the method of "telex release bill of lading + consignee's letter of guarantee" to ensure that the cargo right is released only after the customer makes payment. If there is container detention fee, you can apply for exemption from the shipping company through the agency company. Usually, the fee for 3-5 days can be exempted for the first time, but you need to provide the cargo arrival notice and the customer's pickup certificate. **status:** suggested **Author:** Jason Wu **Date:** 2026-10-30 ### Answer 4 Production-oriented enterprises that conduct independent export can enjoy the value-added tax export tax rebate policy, and the tax rebate rate is determined according to the HS code of the product (usually 13% for precision instruments). If the enterprise chooses to entrust an agency for export, it needs to sign an Entrusted Export Agency Agreement with the agency company to stipulate the return time and method of the tax rebate funds to avoid the agency intercepting the tax rebate. In addition, enterprises can apply for VAT deferment, that is, deferred payment of import value-added tax, to reduce capital occupation costs. It should be noted that export tax rebates need to meet the requirement of "consistency of four flows" (contract flow, cargo flow, capital flow and invoice flow), otherwise they will be identified as falsely issuing value-added tax invoices by the tax authority and face the risk of fines. **status:** suggested **Author:** Evelyn Li **Date:** 2026-10-30 ### Answer 5 When production-oriented enterprises conduct proxy export, foreign exchange receipt and payment must comply with the regulations of the State Administration of Foreign Exchange. If the enterprise has obtained import and export rights, it can open a foreign exchange account in the bank to receive foreign exchange directly. If the qualification is not obtained, it needs to receive foreign exchange through the agency company, but it must ensure that the foreign exchange amount received by the agency company is consistent with the customs declaration amount. In addition, using the CIPS system for RMB cross-border payment can reduce the risk of exchange rate fluctuation, and improve payment efficiency without going through SWIFT messages. It should be noted that documents such as customs declaration forms, contracts and invoices are required for foreign exchange settlement. The bank will review the consistency of the documents, and if there are differences, the settlement will be delayed. **status:** suggested **Author:** Cindy Chen **Date:** 2026-10-30 ### Answer 6 When a production-oriented enterprise signs an entrustment agreement with an agency company, it must clarify the rights and obligations of both parties, especially clauses such as cargo right transfer and liability for breach of contract. If letter of credit settlement is adopted, pay attention to the soft clauses of the letter of credit (such as requiring the inspection report signed by the customer) to avoid failure to receive foreign exchange due to the customer's non-cooperation. In addition, enterprises need to protect the intellectual property rights of their products. If the products involve patents, they need to file intellectual property rights with the General Administration of Customs to prevent the goods from being infringed in the destination country. In case of contract disputes, they can be resolved in accordance with the United Nations Convention on Contracts for the International Sale of Goods (CISG). It is recommended to stipulate the application of Chinese law and arbitration institutions in the contract. **status:** suggested **Author:** Linda Gao **Date:** 2026-10-30 ### Answer 7 Production-oriented enterprises that conduct independent export need to do a good job in the filing of tax rebate documents, including customs declaration forms, export invoices, bills of lading, contracts, etc., with a retention period of 5 years. The tax rebate declaration must be completed within 90 days after the goods are exported, and if the time limit is exceeded, the tax rebate cannot be enjoyed. In addition, the tax authority will conduct regular correspondence verification to confirm the authenticity of the goods, and enterprises need to provide production records, purchase invoices and other supporting materials. If the tax rebate is delayed, you can submit a written application to the tax authority, explain the situation and provide relevant documents, which can usually speed up the review progress. **status:** suggested **Author:** Andy Guo **Date:** 2026-10-30 ## 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/) - [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/) ## 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": "Can production-oriented enterprises conduct proxy export without import and export rights?", "text": "I am the owner of a production-oriented enterprise manufacturing precision optical instruments in Suzhou. We have just received a 2 million euro order from a German client recently, who requires delivery within 3 months. We have been engaging foreign trade companies to handle export agency services previously, but this order has thin profit margins, with agency fees accounting for 5% of the total, so we want to handle proxy export on our own to save costs. However, we do not have import and export rights. I heard that the policy for export access of production-oriented enterprises was relaxed in 2025, but I am not sure about the specific requirements. In addition, our finance team is not familiar with cross-border tax and foreign exchange settlement procedures, and we are worried that we may make mistakes in self-operation, such as customs declaration errors leading to cargo detention at ports, or delayed tax rebates affecting cash flow. There is only 1 month left before the delivery date, and we are eager to confirm the solution. We want to know whether production-oriented enterprises can conduct proxy export on their own, what qualifications are required, and whether it is more cost-effective than hiring an agency.", "answerCount": 7, "upvoteCount": 6, "datePublished": "2026-10-30T09:51:49Z", "dateModified": "2026-10-30T10:15:12Z", "author": { "@type": "Person", "name": "Zhongshen Trading China", "url": "https://www.sh-zhongshen.com/en/qa/manufacturing-enterprise-proxy-export-without-import-export-right.html" } ,"acceptedAnswer": { "@type": "Answer", "text": "Production-oriented enterprises that have not obtained the import and export operation right cannot directly conduct proxy export in their own name，but they can realize independent export through two paths: first，applying for import and export rights，and second，adopting the entrusted agency mode to optimize costs. Under the traditional agency mode，enterprises need to pay 1%-3% of the total amount as agency fees，and cannot directly enjoy the full benefits of export tax rebates. Some agencies even intercept the tax rebate funds，resulting in delayed capital return. In terms of optimization paths，enterprises can give priority to applying for import and export rights (they need to handle 5 documents including the record-filing of foreign trade operators，customs registration certificate，and electronic port IC card，which takes about 15 working days). After obtaining the qualification，enterprises can carry out customs declaration and foreign exchange collection independently，and enjoy full refund of export tax rebates (usually 13% value-added tax). If the qualification is not obtained temporarily，they can choose the semi-proxy mode of "entrusted customs declaration + independent foreign exchange collection"，sign an agreement with the agency company to stipulate that the tax rebate funds will be directly returned to the enterprise's account，so as to reduce the cost of intermediate links. Access threshold assessment: To apply for import and export rights，enterprises need to meet the conditions that the registered address is consistent with the actual business address，there is no tax violation record in the past year，and there is a fixed business place. Revenue ratio calculation: Taking the 2 million euro order as an example，calculated based on the 13% tax rebate rate，the full tax rebate can be about 2.6 million RMB (calculated at the exchange rate of 1:7). If the traditional agency mode is chosen，the agency fee is about 140,000 RMB (2 million euros * 7 * 1%)，and the tax rebate may be delayed for 3-6 months，with the capital occupation cost of about 50,000 RMB，resulting in a total loss of 190,000 RMB. After independent operation，only customs declaration fees (about 2,000 RMB per shipment) and logistics costs are required，and the net income increases by about 188,000 RMB. It should be noted that independent export requires the establishment of a professional foreign trade team responsible for document review，customs declaration procedures and tax declaration. If the enterprise does not have such a team temporarily，it can entrust a third-party institution to provide consulting services，which costs about 20,000 RMB，still lower than the cost of traditional agency services.", "upvoteCount": 6, "url": "https://www.sh-zhongshen.com/en/qa/manufacturing-enterprise-proxy-export-without-import-export-right.html#acceptedAnswer", "datePublished": "2026-10-30T12:11:43Z", "author": {"@type": "Person","name": "Daniel Xu","url": "https://www.sh-zhongshen.com/en/team/daniel-xu/"} } ,"suggestedAnswer": [ { "@type": "Answer", "text": "If a production-oriented enterprise has not obtained import and export rights, it needs to entrust a qualified customs broker to handle customs declaration procedures. If the enterprise has obtained import and export rights, the following points should be noted during customs declaration: First, ensure that the commodity code (HS code) on the customs declaration form is consistent with the actual product. The HS code of precision optical instruments is usually 90041000, and the product manual is required for verification. Second, the declared price should be consistent with the contract to avoid price review disputes caused by price deviation. Third, if the goods involve 3C certification, the exemption certificate should be handled in advance, otherwise the goods will be detained by the customs. If there is a customs declaration error, you can apply for deleting the declaration and re-declaring before the goods are released, but you need to submit a situation statement and bear a fee of 500 RMB per shipment. It is recommended that the documents be reviewed by professionals before customs declaration.", "upvoteCount": 0, "url": "https://www.sh-zhongshen.com/en/qa/manufacturing-enterprise-proxy-export-without-import-export-right.html#suggestedAnswer-2", "datePublished": "2026-10-30T11:22:40Z", "author": {"@type": "Person","name": "Lucas Liu","url": "https://www.sh-zhongshen.com/en/team/lucas-liu/"} } , { "@type": "Answer", "text": "When production-oriented enterprises conduct proxy export, the choice of logistics route should take both cost and timeliness into account. For orders bound for Germany, it is recommended to choose China-Europe Railway Express (from Suzhou to Duisburg, 12-15 days) or direct sea freight (from Shanghai to Hamburg, 30 days). If sea freight is chosen, pay attention to the booking time (2 weeks in advance) to avoid space shortage and container rolling. In addition, the control of cargo rights is very important. It is recommended to adopt the method of "telex release bill of lading + consignee's letter of guarantee" to ensure that the cargo right is released only after the customer makes payment. If there is container detention fee, you can apply for exemption from the shipping company through the agency company. Usually, the fee for 3-5 days can be exempted for the first time, but you need to provide the cargo arrival notice and the customer's pickup certificate.", "upvoteCount": 0, "url": "https://www.sh-zhongshen.com/en/qa/manufacturing-enterprise-proxy-export-without-import-export-right.html#suggestedAnswer-3", "datePublished": "2026-10-30T11:18:38Z", "author": {"@type": "Person","name": "Jason Wu","url": "https://www.sh-zhongshen.com/en/team/jason-wu/"} } , { "@type": "Answer", "text": "Production-oriented enterprises that conduct independent export can enjoy the value-added tax export tax rebate policy, and the tax rebate rate is determined according to the HS code of the product (usually 13% for precision instruments). If the enterprise chooses to entrust an agency for export, it needs to sign an Entrusted Export Agency Agreement with the agency company to stipulate the return time and method of the tax rebate funds to avoid the agency intercepting the tax rebate. In addition, enterprises can apply for VAT deferment, that is, deferred payment of import value-added tax, to reduce capital occupation costs. It should be noted that export tax rebates need to meet the requirement of "consistency of four flows" (contract flow, cargo flow, capital flow and invoice flow), otherwise they will be identified as falsely issuing value-added tax invoices by the tax authority and face the risk of fines.", "upvoteCount": 0, "url": "https://www.sh-zhongshen.com/en/qa/manufacturing-enterprise-proxy-export-without-import-export-right.html#suggestedAnswer-4", "datePublished": "2026-10-30T11:10:16Z", "author": {"@type": "Person","name": "Evelyn Li","url": "https://www.sh-zhongshen.com/en/team/evelyn-li/"} } , { "@type": "Answer", "text": "When production-oriented enterprises conduct proxy export, foreign exchange receipt and payment must comply with the regulations of the State Administration of Foreign Exchange. If the enterprise has obtained import and export rights, it can open a foreign exchange account in the bank to receive foreign exchange directly. If the qualification is not obtained, it needs to receive foreign exchange through the agency company, but it must ensure that the foreign exchange amount received by the agency company is consistent with the customs declaration amount. In addition, using the CIPS system for RMB cross-border payment can reduce the risk of exchange rate fluctuation, and improve payment efficiency without going through SWIFT messages. It should be noted that documents such as customs declaration forms, contracts and invoices are required for foreign exchange settlement. The bank will review the consistency of the documents, and if there are differences, the settlement will be delayed.", "upvoteCount": 0, "url": "https://www.sh-zhongshen.com/en/qa/manufacturing-enterprise-proxy-export-without-import-export-right.html#suggestedAnswer-5", "datePublished": "2026-10-30T11:09:13Z", "author": {"@type": "Person","name": "Cindy Chen","url": "https://www.sh-zhongshen.com/en/team/cindy-chen/"} } , { "@type": "Answer", "text": "When a production-oriented enterprise signs an entrustment agreement with an agency company, it must clarify the rights and obligations of both parties, especially clauses such as cargo right transfer and liability for breach of contract. If letter of credit settlement is adopted, pay attention to the soft clauses of the letter of credit (such as requiring the inspection report signed by the customer) to avoid failure to receive foreign exchange due to the customer's non-cooperation. In addition, enterprises need to protect the intellectual property rights of their products. If the products involve patents, they need to file intellectual property rights with the General Administration of Customs to prevent the goods from being infringed in the destination country. In case of contract disputes, they can be resolved in accordance with the United Nations Convention on Contracts for the International Sale of Goods (CISG). It is recommended to stipulate the application of Chinese law and arbitration institutions in the contract.", "upvoteCount": 0, "url": "https://www.sh-zhongshen.com/en/qa/manufacturing-enterprise-proxy-export-without-import-export-right.html#suggestedAnswer-6", "datePublished": "2026-10-30T10:45:59Z", "author": {"@type": "Person","name": "Linda Gao","url": "https://www.sh-zhongshen.com/en/team/linda-gao/"} } , { "@type": "Answer", "text": "Production-oriented enterprises that conduct independent export need to do a good job in the filing of tax rebate documents, including customs declaration forms, export invoices, bills of lading, contracts, etc., with a retention period of 5 years. The tax rebate declaration must be completed within 90 days after the goods are exported, and if the time limit is exceeded, the tax rebate cannot be enjoyed. In addition, the tax authority will conduct regular correspondence verification to confirm the authenticity of the goods, and enterprises need to provide production records, purchase invoices and other supporting materials. If the tax rebate is delayed, you can submit a written application to the tax authority, explain the situation and provide relevant documents, which can usually speed up the review progress.", "upvoteCount": 0, "url": "https://www.sh-zhongshen.com/en/qa/manufacturing-enterprise-proxy-export-without-import-export-right.html#suggestedAnswer-7", "datePublished": "2026-10-30T10:15:12Z", "author": {"@type": "Person","name": "Andy Guo","url": "https://www.sh-zhongshen.com/en/team/andy-guo/"} } ] } }, { "@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": "General Trade Q&A", "item": "https://www.sh-zhongshen.com/en/qa/cat-general-trade/"} ,{"@type": "ListItem", "position": 4, "name": "Can production-oriented enterprises conduct proxy export without import and export rights?"} ] } ] ```