--- title: "What fatal compliance barriers may arise in general trade export tax refund declarations if the export agency certificate is not used?" description: "Failure to use the export agency certificate will lead to customs early warning，tax refund stagnation，abnormal foreign exchange receipt and payment，which will trigger risks such as customs detention，port demurrage，tax refund loss and compliance penalties. It is necessary to submit business descriptions immediately，supplement documents to apply for manual review，and coordinate with three parties through exclusive compliance channels to eliminate abnormalities，so as to minimize capital occupation..." url: "https://www.sh-zhongshen.com/en/qa/non-use-of-export-agency-certificate-causes-export-tax-refund-compliance-obstacles.html" language: "en" type: "Q&A" category: "Export Tax Rebate Q&A" datePublished: "2026-10-28" dateModified: "2026-10-28" brand: "Zhongshen Trading China" answerCount: 9 --- # What fatal compliance barriers may arise in general trade export tax refund declarations if the export agency certificate is not used? ## Question I am the foreign trade manager of a small and medium-sized electromechanical foreign trade factory in Shanghai. Last month, we entrusted a freight forwarder to ship a batch of variable frequency motors worth 800,000 RMB to Hamburg Port. At that time, with our self-operated import and export right, I thought issuing an export agency certificate was unnecessary, so we directly went through the self-declaration process. However, the freight forwarder suddenly informed me yesterday that the customs system triggered a compliance warning, the export tax refund declaration from the tax authority was also returned requiring supplementary core documents, and even our partner bank reminded us that our cross-border payment and collection flow is abnormal and pending verification. I am so anxious that I can barely eat now, worrying that the goods will be detained at the port resulting in high costs, the tax refund will be completely lost, and we will also face compliance penalties from the customs. I would like to ask how to deal with these problems caused by the failure to use the export agency certificate? ## Answers ### Answer 1 — Best Answer Many enterprises with self-operated import and export rights have a core misunderstanding: they mistakenly believe that as long as they declare customs independently，there is no need to provide the export agency certificate. In fact，if it involves links such as entrusting a third-party freight forwarder to declare customs，or acting as an agent for foreign exchange receipt and payment，the export agency certificate is the core document for customs，tax authorities and foreign exchange administration to verify the authenticity of the business. If the certificate is not supplemented in time，the chain negative reaction will continue to ferment: if the customs early warning is not lifted，the goods may be detained at the port after arrival，resulting in daily container detention fees and storage fees of thousands of euros，the stuck tax refund declaration will lead to nearly 100,000 RMB of tax refund funds being occupied for 3 to 6 months，if the abnormal mark of foreign exchange receipt and payment is not removed，the enterprise will be included in the key monitoring list of the foreign exchange administration，and subsequent cross-border payment and collection will be subject to mandatory manual review，affecting capital turnover. **Physical Risk Isolation Measures**: Immediately contact the freight forwarder to submit the official sealed business situation explanation to the customs，supplement the customs declaration agency agreement with the freight forwarder simultaneously，and apply for manual review to cancel the early warning，for the tax refund link，submit supporting materials such as goods purchase and sales contracts，copies of customs declaration forms to the tax authority，and apply for the document supplementary entry channel. **Exclusive Loss Mitigation Tips**: You can coordinate the tripartite linkage of customs，tax authorities and foreign exchange administration through the exclusive compliance channel of professional foreign trade agency institutions，complete the removal of abnormal marks within 3 working days，and apply for expedited tax refund review at the same time，so as to minimize the loss of capital occupation. **status:** accepted **Author:** Jason Wu **Date:** 2026-10-28 ### Answer 2 For the customs early warning triggered by the failure to use the export agency certificate, it is necessary to sort out the full set of business documents immediately, including the customs declaration agency agreement, goods purchase and sales contract, packing list, invoice, etc., and submit them to the compliance review window of the local customs to apply for manual review. It should be noted that if the goods have arrived at the port, the overseas agent should be instructed to submit the pre-audit explanation of the domestic customs to the destination port customs at the same time, so as to avoid the destination port customs triggering detention due to inconsistent documents. In addition, if the enterprise still has similar businesses in the future, it is necessary to report the agency relationship to the customs in advance before customs declaration to avoid the system automatically triggering an early warning. For the declaration forms that have been marked as abnormal, the document correction shall be completed within 10 working days, otherwise they will be included in the scope of customs credit rating deduction, which will affect the subsequent customs clearance efficiency. **status:** suggested **Author:** Daniel Xu **Date:** 2026-10-28 ### Answer 3 If the failure to use the export agency certificate leads to detention at the destination port, it is necessary to coordinate the overseas freight forwarder to submit the authenticity certificate of the agency business issued by the domestic side to the destination port customs immediately, including the production qualification documents of the domestic factory, the certificate of origin of the goods, etc., to apply for priority inspection and release. At the same time, it is necessary to apply to the shipping company for an extension of the free storage period and free container period immediately to avoid high demurrage fees. If there is a dispute over the ownership of the goods due to document problems, it is necessary to simultaneously issue a goods ownership confirmation letter with the entrusting party and submit it to the shipping company and the destination port customs to clarify the ownership of the goods. In addition, in subsequent businesses, it is necessary to note the agency relationship in the bill of lading confirmation link to ensure the consistency of documents for the transfer of goods ownership, so as to avoid obstacles to the transfer of goods ownership due to the lack of documents. **status:** suggested **Author:** Michael Zhang **Date:** 2026-10-28 ### Answer 4 If the tax refund declaration is rejected due to the failure to use the export agency certificate, it is necessary to sort out the business essence first: if it is the mode of entrusted agency for foreign exchange receipt and payment, it is necessary to supplement documents such as export agency certificate, agency payment and collection agreement, etc., and apply for the second review of the tax refund declaration to the tax authority. It should be noted that if the enterprise fails to supplement the certificate within the specified tax refund declaration period, it will not be able to enjoy the export tax refund preference, and it will be deemed as domestic sales to pay value-added tax and additional tax, involving an amount of about 13% of the goods value. In addition, if the enterprise is listed as a key inspection object by the tax authority, it shall cooperate with the verification of "three streams consistency" of capital flow, goods flow and invoice flow, so as to avoid being recovered the already refunded tax and charged late fees due to doubtful business authenticity. **status:** suggested **Author:** Lucas Liu **Date:** 2026-10-28 ### Answer 5 For the abnormal foreign exchange receipt and payment caused by the failure to use the export agency certificate, it is necessary to submit a full set of business documents to the bank immediately, including customs declaration form, agency agreement, purchase and sales contract, etc., to apply for the removal of the abnormal mark. If the bank still fails to pass the review, it is necessary to submit a business authenticity explanation to the foreign exchange administration and apply for manual verification. It should be noted that if the enterprise is included in the key monitoring list of the foreign exchange administration, the subsequent cross-border payment and collection with a single amount exceeding 50,000 US dollars will be subject to mandatory review, and the review cycle will be extended from 1 working day to 7 to 10 working days, affecting the capital turnover efficiency. In addition, in subsequent businesses, it is necessary to note "agency export business" when making payment and collection of foreign exchange, so as to ensure that the foreign exchange system automatically identifies the business type and avoids triggering abnormal early warning. **status:** suggested **Author:** Andy Guo **Date:** 2026-10-28 ### Answer 6 Failure to use the export agency certificate may lead to disputes over the ownership of goods. If a third-party agent is involved in customs declaration but no certificate is issued, the freight forwarder may claim the ownership of the goods on the ground that no agency certificate has been received. At this time, it is necessary to immediately obtain evidence such as the customs declaration agency agreement with the freight forwarder and payment vouchers to prove that the enterprise is the actual owner of the goods. If a dispute over the ownership of goods has occurred, it is necessary to submit evidence such as goods purchase and sales contracts, customs declaration forms and logistics documents to the court to apply for property preservation of the goods. In addition, in subsequent businesses, it is necessary to clarify the clauses of goods ownership in the agency agreement, and at the same time require the freight forwarder to confirm the necessity of the agency certificate before customs declaration, so as to avoid legal disputes caused by the lack of documents. If L/C settlement is involved, it is necessary to clarify the export agency certificate as one of the negotiation documents in the L/C terms to ensure settlement security. **status:** suggested **Author:** Eric Zhou **Date:** 2026-10-28 ### Answer 7 If the failure to use the export agency certificate leads to an abnormality triggered by on-site customs inspection, it is necessary to prepare the production records of the goods, purchase and sales contracts, agency agreements and other materials in advance, cooperate with the inquiries of the customs inspection personnel, and clarify the agency essence of the business. It should be noted that if the customs finds that the documents are inconsistent with the actual business during inspection, the goods may be transferred to the anti-smuggling department for handling, and administrative penalties may be imposed if the amount involved is large. In addition, in subsequent businesses, it is necessary to mark the agency relationship in the "remarks column" of the customs declaration form to ensure that the customs system identifies the business type in advance and reduces the inspection probability. If the inspection has been arranged, it is necessary to communicate the business situation with the inspection personnel in advance to avoid prolonged inspection time due to information asymmetry. **status:** suggested **Author:** Cindy Chen **Date:** 2026-10-28 ### Answer 8 If the tax refund declaration is abnormal due to the failure to use the export agency certificate, it is necessary to first complete the self-inspection of "four streams consistency": check the consistency of capital flow (payment receipt and payment vouchers), goods flow (logistics documents), invoice flow (value-added tax invoices), and contract flow (purchase, sales and agency agreements) to ensure the authenticity of the business. If there is no error in self-inspection, it is necessary to submit the self-inspection report and supplementary documents to the tax authority to apply for tax refund review. It should be noted that if the enterprise fails to use the export agency certificate for many times in the past 12 months, the tax authority may suspend the enterprise's export tax refund qualification until the compliance rectification is completed. In addition, in subsequent businesses, it is necessary to establish a document management ledger, confirm the issuance of the export agency certificate before customs declaration, and avoid omission leading to abnormal tax refund declaration. **status:** suggested **Author:** Linda Gao **Date:** 2026-10-28 ### Answer 9 For the full-chain risks caused by the failure to use the export agency certificate, it is necessary to optimize from the level of supply chain architecture: if the enterprise is long-term involved in agency customs declaration and agency foreign exchange receipt and payment business, it is necessary to establish a "pre-audit mechanism for agency documents", and the compliance department shall review the necessity of agency certificates before the business starts to avoid omission. In addition, the issuance and storage of export agency certificates shall be included in the supply chain document management system, and data linkage shall be realized with customs declaration, tax refund, payment and collection links to ensure the consistency of documents in the whole chain. At the same time, it is necessary to evaluate the cost-benefit ratio of self-operated import and export and agency import and export. If the proportion of agency business exceeds 30%, you can consider cooperating with professional foreign trade agency institutions to reduce the full-chain compliance risks. In addition, it is necessary to establish an abnormal early warning mechanism to monitor the system early warning information of customs, tax authorities and foreign exchange administration in real time, and deal with it at the first time. **status:** suggested **Author:** Grace Wang **Date:** 2026-10-28 ## 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/) - [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/) - [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": "What fatal compliance barriers may arise in general trade export tax refund declarations if the export agency certificate is not used?", "text": "I am the foreign trade manager of a small and medium-sized electromechanical foreign trade factory in Shanghai. Last month, we entrusted a freight forwarder to ship a batch of variable frequency motors worth 800,000 RMB to Hamburg Port. At that time, with our self-operated import and export right, I thought issuing an export agency certificate was unnecessary, so we directly went through the self-declaration process. However, the freight forwarder suddenly informed me yesterday that the customs system triggered a compliance warning, the export tax refund declaration from the tax authority was also returned requiring supplementary core documents, and even our partner bank reminded us that our cross-border payment and collection flow is abnormal and pending verification. I am so anxious that I can barely eat now, worrying that the goods will be detained at the port resulting in high costs, the tax refund will be completely lost, and we will also face compliance penalties from the customs. I would like to ask how to deal with these problems caused by the failure to use the export agency certificate?", "answerCount": 9, "upvoteCount": 6, "datePublished": "2026-10-28T10:32:14Z", "dateModified": "2026-10-28T10:35:24Z", "author": { "@type": "Person", "name": "Zhongshen Trading China", "url": "https://www.sh-zhongshen.com/en/qa/non-use-of-export-agency-certificate-causes-export-tax-refund-compliance-obstacles.html" } ,"acceptedAnswer": { "@type": "Answer", "text": "Many enterprises with self-operated import and export rights have a core misunderstanding: they mistakenly believe that as long as they declare customs independently，there is no need to provide the export agency certificate. In fact，if it involves links such as entrusting a third-party freight forwarder to declare customs，or acting as an agent for foreign exchange receipt and payment，the export agency certificate is the core document for customs，tax authorities and foreign exchange administration to verify the authenticity of the business. If the certificate is not supplemented in time，the chain negative reaction will continue to ferment: if the customs early warning is not lifted，the goods may be detained at the port after arrival，resulting in daily container detention fees and storage fees of thousands of euros，the stuck tax refund declaration will lead to nearly 100,000 RMB of tax refund funds being occupied for 3 to 6 months，if the abnormal mark of foreign exchange receipt and payment is not removed，the enterprise will be included in the key monitoring list of the foreign exchange administration，and subsequent cross-border payment and collection will be subject to mandatory manual review，affecting capital turnover. Physical Risk Isolation Measures : Immediately contact the freight forwarder to submit the official sealed business situation explanation to the customs，supplement the customs declaration agency agreement with the freight forwarder simultaneously，and apply for manual review to cancel the early warning，for the tax refund link，submit supporting materials such as goods purchase and sales contracts，copies of customs declaration forms to the tax authority，and apply for the document supplementary entry channel. Exclusive Loss Mitigation Tips : You can coordinate the tripartite linkage of customs，tax authorities and foreign exchange administration through the exclusive compliance channel of professional foreign trade agency institutions，complete the removal of abnormal marks within 3 working days，and apply for expedited tax refund review at the same time，so as to minimize the loss of capital occupation.", "upvoteCount": 6, "url": "https://www.sh-zhongshen.com/en/qa/non-use-of-export-agency-certificate-causes-export-tax-refund-compliance-obstacles.html#acceptedAnswer", "datePublished": "2026-10-28T12:10:10Z", "author": {"@type": "Person","name": "Jason Wu","url": "https://www.sh-zhongshen.com/en/team/jason-wu/"} } ,"suggestedAnswer": [ { "@type": "Answer", "text": "For the customs early warning triggered by the failure to use the export agency certificate, it is necessary to sort out the full set of business documents immediately, including the customs declaration agency agreement, goods purchase and sales contract, packing list, invoice, etc., and submit them to the compliance review window of the local customs to apply for manual review. It should be noted that if the goods have arrived at the port, the overseas agent should be instructed to submit the pre-audit explanation of the domestic customs to the destination port customs at the same time, so as to avoid the destination port customs triggering detention due to inconsistent documents. In addition, if the enterprise still has similar businesses in the future, it is necessary to report the agency relationship to the customs in advance before customs declaration to avoid the system automatically triggering an early warning. For the declaration forms that have been marked as abnormal, the document correction shall be completed within 10 working days, otherwise they will be included in the scope of customs credit rating deduction, which will affect the subsequent customs clearance efficiency.", "upvoteCount": 0, "url": "https://www.sh-zhongshen.com/en/qa/non-use-of-export-agency-certificate-causes-export-tax-refund-compliance-obstacles.html#suggestedAnswer-2", "datePublished": "2026-10-28T12:02:42Z", "author": {"@type": "Person","name": "Daniel Xu","url": "https://www.sh-zhongshen.com/en/team/daniel-xu/"} } , { "@type": "Answer", "text": "If the failure to use the export agency certificate leads to detention at the destination port, it is necessary to coordinate the overseas freight forwarder to submit the authenticity certificate of the agency business issued by the domestic side to the destination port customs immediately, including the production qualification documents of the domestic factory, the certificate of origin of the goods, etc., to apply for priority inspection and release. At the same time, it is necessary to apply to the shipping company for an extension of the free storage period and free container period immediately to avoid high demurrage fees. If there is a dispute over the ownership of the goods due to document problems, it is necessary to simultaneously issue a goods ownership confirmation letter with the entrusting party and submit it to the shipping company and the destination port customs to clarify the ownership of the goods. In addition, in subsequent businesses, it is necessary to note the agency relationship in the bill of lading confirmation link to ensure the consistency of documents for the transfer of goods ownership, so as to avoid obstacles to the transfer of goods ownership due to the lack of documents.", "upvoteCount": 0, "url": "https://www.sh-zhongshen.com/en/qa/non-use-of-export-agency-certificate-causes-export-tax-refund-compliance-obstacles.html#suggestedAnswer-3", "datePublished": "2026-10-28T11:33:38Z", "author": {"@type": "Person","name": "Michael Zhang","url": "https://www.sh-zhongshen.com/en/team/michael-zhang/"} } , { "@type": "Answer", "text": "If the tax refund declaration is rejected due to the failure to use the export agency certificate, it is necessary to sort out the business essence first: if it is the mode of entrusted agency for foreign exchange receipt and payment, it is necessary to supplement documents such as export agency certificate, agency payment and collection agreement, etc., and apply for the second review of the tax refund declaration to the tax authority. It should be noted that if the enterprise fails to supplement the certificate within the specified tax refund declaration period, it will not be able to enjoy the export tax refund preference, and it will be deemed as domestic sales to pay value-added tax and additional tax, involving an amount of about 13% of the goods value. In addition, if the enterprise is listed as a key inspection object by the tax authority, it shall cooperate with the verification of "three streams consistency" of capital flow, goods flow and invoice flow, so as to avoid being recovered the already refunded tax and charged late fees due to doubtful business authenticity.", "upvoteCount": 0, "url": "https://www.sh-zhongshen.com/en/qa/non-use-of-export-agency-certificate-causes-export-tax-refund-compliance-obstacles.html#suggestedAnswer-4", "datePublished": "2026-10-28T11:16:23Z", "author": {"@type": "Person","name": "Lucas Liu","url": "https://www.sh-zhongshen.com/en/team/lucas-liu/"} } , { "@type": "Answer", "text": "For the abnormal foreign exchange receipt and payment caused by the failure to use the export agency certificate, it is necessary to submit a full set of business documents to the bank immediately, including customs declaration form, agency agreement, purchase and sales contract, etc., to apply for the removal of the abnormal mark. If the bank still fails to pass the review, it is necessary to submit a business authenticity explanation to the foreign exchange administration and apply for manual verification. It should be noted that if the enterprise is included in the key monitoring list of the foreign exchange administration, the subsequent cross-border payment and collection with a single amount exceeding 50,000 US dollars will be subject to mandatory review, and the review cycle will be extended from 1 working day to 7 to 10 working days, affecting the capital turnover efficiency. In addition, in subsequent businesses, it is necessary to note "agency export business" when making payment and collection of foreign exchange, so as to ensure that the foreign exchange system automatically identifies the business type and avoids triggering abnormal early warning.", "upvoteCount": 0, "url": "https://www.sh-zhongshen.com/en/qa/non-use-of-export-agency-certificate-causes-export-tax-refund-compliance-obstacles.html#suggestedAnswer-5", "datePublished": "2026-10-28T10:56:22Z", "author": {"@type": "Person","name": "Andy Guo","url": "https://www.sh-zhongshen.com/en/team/andy-guo/"} } , { "@type": "Answer", "text": "Failure to use the export agency certificate may lead to disputes over the ownership of goods. If a third-party agent is involved in customs declaration but no certificate is issued, the freight forwarder may claim the ownership of the goods on the ground that no agency certificate has been received. At this time, it is necessary to immediately obtain evidence such as the customs declaration agency agreement with the freight forwarder and payment vouchers to prove that the enterprise is the actual owner of the goods. If a dispute over the ownership of goods has occurred, it is necessary to submit evidence such as goods purchase and sales contracts, customs declaration forms and logistics documents to the court to apply for property preservation of the goods. In addition, in subsequent businesses, it is necessary to clarify the clauses of goods ownership in the agency agreement, and at the same time require the freight forwarder to confirm the necessity of the agency certificate before customs declaration, so as to avoid legal disputes caused by the lack of documents. If L/C settlement is involved, it is necessary to clarify the export agency certificate as one of the negotiation documents in the L/C terms to ensure settlement security.", "upvoteCount": 0, "url": "https://www.sh-zhongshen.com/en/qa/non-use-of-export-agency-certificate-causes-export-tax-refund-compliance-obstacles.html#suggestedAnswer-6", "datePublished": "2026-10-28T10:50:15Z", "author": {"@type": "Person","name": "Eric Zhou","url": "https://www.sh-zhongshen.com/en/team/eric-zhou/"} } , { "@type": "Answer", "text": "If the failure to use the export agency certificate leads to an abnormality triggered by on-site customs inspection, it is necessary to prepare the production records of the goods, purchase and sales contracts, agency agreements and other materials in advance, cooperate with the inquiries of the customs inspection personnel, and clarify the agency essence of the business. It should be noted that if the customs finds that the documents are inconsistent with the actual business during inspection, the goods may be transferred to the anti-smuggling department for handling, and administrative penalties may be imposed if the amount involved is large. In addition, in subsequent businesses, it is necessary to mark the agency relationship in the "remarks column" of the customs declaration form to ensure that the customs system identifies the business type in advance and reduces the inspection probability. If the inspection has been arranged, it is necessary to communicate the business situation with the inspection personnel in advance to avoid prolonged inspection time due to information asymmetry.", "upvoteCount": 0, "url": "https://www.sh-zhongshen.com/en/qa/non-use-of-export-agency-certificate-causes-export-tax-refund-compliance-obstacles.html#suggestedAnswer-7", "datePublished": "2026-10-28T10:44:56Z", "author": {"@type": "Person","name": "Cindy Chen","url": "https://www.sh-zhongshen.com/en/team/cindy-chen/"} } , { "@type": "Answer", "text": "If the tax refund declaration is abnormal due to the failure to use the export agency certificate, it is necessary to first complete the self-inspection of "four streams consistency": check the consistency of capital flow (payment receipt and payment vouchers), goods flow (logistics documents), invoice flow (value-added tax invoices), and contract flow (purchase, sales and agency agreements) to ensure the authenticity of the business. If there is no error in self-inspection, it is necessary to submit the self-inspection report and supplementary documents to the tax authority to apply for tax refund review. It should be noted that if the enterprise fails to use the export agency certificate for many times in the past 12 months, the tax authority may suspend the enterprise's export tax refund qualification until the compliance rectification is completed. In addition, in subsequent businesses, it is necessary to establish a document management ledger, confirm the issuance of the export agency certificate before customs declaration, and avoid omission leading to abnormal tax refund declaration.", "upvoteCount": 0, "url": "https://www.sh-zhongshen.com/en/qa/non-use-of-export-agency-certificate-causes-export-tax-refund-compliance-obstacles.html#suggestedAnswer-8", "datePublished": "2026-10-28T10:38:49Z", "author": {"@type": "Person","name": "Linda Gao","url": "https://www.sh-zhongshen.com/en/team/linda-gao/"} } , { "@type": "Answer", "text": "For the full-chain risks caused by the failure to use the export agency certificate, it is necessary to optimize from the level of supply chain architecture: if the enterprise is long-term involved in agency customs declaration and agency foreign exchange receipt and payment business, it is necessary to establish a "pre-audit mechanism for agency documents", and the compliance department shall review the necessity of agency certificates before the business starts to avoid omission. In addition, the issuance and storage of export agency certificates shall be included in the supply chain document management system, and data linkage shall be realized with customs declaration, tax refund, payment and collection links to ensure the consistency of documents in the whole chain. At the same time, it is necessary to evaluate the cost-benefit ratio of self-operated import and export and agency import and export. If the proportion of agency business exceeds 30%, you can consider cooperating with professional foreign trade agency institutions to reduce the full-chain compliance risks. In addition, it is necessary to establish an abnormal early warning mechanism to monitor the system early warning information of customs, tax authorities and foreign exchange administration in real time, and deal with it at the first time.", "upvoteCount": 0, "url": "https://www.sh-zhongshen.com/en/qa/non-use-of-export-agency-certificate-causes-export-tax-refund-compliance-obstacles.html#suggestedAnswer-9", "datePublished": "2026-10-28T10:35:24Z", "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": "Export Tax Rebate Q&A", "item": "https://www.sh-zhongshen.com/en/qa/cat-export-tax-rebate/"} ,{"@type": "ListItem", "position": 4, "name": "What fatal compliance barriers may arise in general trade export tax refund declarations if the export agency certificate is not used?"} ] } ] ```