---
title: "Are Overseas Freight Forwarding Services Part of Formal Import and Export Business?"
description: "Many enterprises mistakenly believe that entrusting an overseas freight forwarder means they have completed their import and export business，but there are actually compliance risks. The expert team of Zhongshen pointed out that freight forwarders are only responsible for the logistics links. Enterprises need to clarify their own principal responsibilities in procedures such as customs declaration，foreign exchange receipt and payment，and ensure the legal implementation of import and export busine..."
url: "https://www.sh-zhongshen.com/en/qa/overseas-freight-forwarder-import-export-category.html"
language: "en"
type: "Q&A"
category: "Freight Forwarding Q&A"
datePublished: "2026-10-10"
dateModified: "2026-10-10"
brand: "Zhongshen Trading China"
answerCount: 7
---

# Are Overseas Freight Forwarding Services Part of Formal Import and Export Business?

## Question

 I am the person in charge of a newly established cross-border e-commerce enterprise. Recently, I entrusted an overseas freight forwarder to handle the cargo transportation from Germany to Shanghai. I always thought that as long as I found a freight forwarder, I had completed the import and export business, but last week the customs suddenly called asking for proof of import and export operation rights, which made me panic. The freight forwarder said they are only responsible for transportation and do not handle customs declaration and foreign exchange receipt and payment. This left me confused — does entrusting an overseas freight forwarder not count as engaging in import and export business? I have invested so much capital, and if the goods are detained or fined due to this compliance issue, the losses will be huge. I want to ask the experts: Does an overseas freight forwarder actually count as part of the import and export business? What should I do now to complete the compliance procedures and avoid risks? 

## Answers
                            
### Answer 1 — Best Answer

Many enterprises share the same misunderstanding as you: equating overseas freight forwarding services with import and export business itself. In fact，freight forwarders only undertake the execution links of cross-border logistics，such as booking space，transportation，pickup of goods，etc。and do not involve the core compliance links of import and export business (such as customs declaration，foreign exchange receipt and payment，tax declaration).

If an enterprise ignores its own principal responsibilities，it may trigger a chain of negative consequences: the customs will detain the goods because the enterprise has not obtained the import and export operation rights or made false declarations，resulting in additional costs such as demurrage and warehouse fees，the tax authorities will trigger tax investigations and even tax recovery due to the inconsistency between foreign exchange receipt and payment data and customs declaration data，in the long run，the enterprise's credit rating will decline，affecting subsequent customs clearance efficiency.

For physical risk isolation measures，it is necessary to immediately clarify the rights and responsibilities boundaries: supplement an agreement with the freight forwarder and require them to provide all documents for the logistics links (such as bill of lading，manifest，packing list)，at the same time，entrust a qualified foreign trade agency company to handle compliance procedures such as customs declaration and foreign exchange receipt and payment，to ensure the consistency of cargo flow，capital flow and document flow.

**Exclusive Emergency Loss Prevention Tips**: 1. Apply for temporary import and export operation rights urgently (if not yet handled)，or entrust an agency company to use their qualifications to declare customs with dual titles，2. Submit a situation explanation to the customs，attach the logistics documents of the freight forwarder，and strive for lenient treatment，3. In subsequent businesses，establish a dual review mechanism of "logistics + compliance". Before entrusting a freight forwarder for each batch of goods，first have the compliance team confirm that all procedures are complete.

**status:** accepted
**Author:** Michael Zhang
**Date:** 2026-10-10

### Answer 2

From the perspective of the customs, overseas freight forwarders are not the responsible subjects of import and export business. As the cargo owner, the enterprise must hold the import and export operation rights (or entrust a qualified agent) to declare to the customs. If you have not obtained the operation rights, you can entrust a foreign trade agency company to declare customs with dual titles, that is, the operating unit is the agency company and the consignee unit is your enterprise.

Please note that the "operating unit" on the customs declaration form must be consistent with the foreign exchange receipt and payment subject, otherwise it will trigger customs valuation disputes or foreign exchange inspections. It is recommended that you supplement the agency agreement as soon as possible to ensure that the customs declaration data matches the actual business.

**status:** suggested
**Author:** Daniel Xu
**Date:** 2026-10-10

### Answer 3

The core responsibilities of overseas freight forwarders are logistics path optimization and cargo right control, rather than import and export compliance. In your case, if the bill of lading provided by the freight forwarder is not properly endorsed, it may lead to loss of cargo rights.

It is recommended that you check the "consignee" column of the bill of lading: if it is "to order", you need to endorse and transfer it to the domestic customs clearance subject in time; if it is an overseas agent, you need to confirm that they are qualified to transfer the cargo rights. In addition, all documents for the logistics links (such as packing list, bill of lading copy) need to be retained as supporting materials for customs inspection, to avoid container inspection due to missing documents.

**status:** suggested
**Author:** Lucas Liu
**Date:** 2026-10-10

### Answer 4

From the tax perspective, import and export business involves value-added tax, tariffs, etc., while the service fee of overseas freight forwarders can only be deducted as logistics costs and cannot replace tax declaration in import and export links. If you have not completed the export tax rebate filing, even if the goods have arrived in China, you cannot enjoy the tax rebate preferences.

It is recommended that you entrust a tax consultant to sort out the business process, confirm whether it meets the VAT deferral conditions, and reduce immediate tax expenditures; at the same time, standardize the foreign exchange receipt and payment path to avoid tax investigations caused by unclear capital flow.

**status:** suggested
**Author:** Andy Guo
**Date:** 2026-10-10

### Answer 5

Cross-border foreign exchange receipt and payment must comply with foreign exchange management regulations, and overseas freight forwarders cannot replace enterprises to complete the foreign exchange receipt and payment procedures. You need to handle import and export foreign exchange receipt and payment through a qualified bank to ensure the consistency of capital flow and cargo flow.

If you use an offshore account for foreign exchange receipt and payment, you need to provide the bank with supporting materials such as customs declaration forms and bills of lading to avoid account freezing. It is recommended that you open the CIPS RMB cross-border payment channel to optimize foreign exchange purchase rates, and retain all foreign exchange receipt and payment vouchers for foreign exchange administration bureau inspection.

**status:** suggested
**Author:** Grace Wang
**Date:** 2026-10-10

### Answer 6

In international trade contracts, it is necessary to clarify the rights and responsibilities boundaries between the freight forwarder and the enterprise. If the agreement between you and the overseas freight forwarder does not stipulate compliance responsibilities, it may lead to disputes.

It is recommended that you supplement the agreement clauses to require the freight forwarder to provide logistics documents that meet the requirements of the Chinese customs; at the same time, sign a force majeure clause as a fallback to deal with emergencies in the logistics links (such as slot cutting and space shortage). In addition, if the goods involve intellectual property rights, you need to complete customs protection filing in advance to avoid goods being detained.

**status:** suggested
**Author:** Kevin Lin
**Date:** 2026-10-10

### Answer 7

Export tax rebate needs to meet the "four flows consistency" (cargo flow, capital flow, document flow, invoice flow). The logistics documents of overseas freight forwarders are only part of the cargo flow.

You also need to provide customs declaration forms, special value-added tax invoices, foreign exchange receipt vouchers, etc. If you have not received the foreign exchange, you need to complete the foreign exchange receipt verification before declaring the tax rebate; if the document filing is incomplete, the tax authorities will reject the tax rebate application. It is recommended that you establish a document management system and retain the documents of each batch of goods for at least 5 years for audit inspection.

**status:** suggested
**Author:** Victor Sun
**Date:** 2026-10-10

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