--- title: "Which party should be listed as the customs declaration subject in agency import business, the consignor or the agent?" description: "Clarification of declaration subject and right and responsibility ownership is a common pain point for enterprises in agency import business，as confusion may easily lead to customs penalties or tax risks. It should be clarified that customs declaration shall be filed in the name of the agent，the taxpayer is the consignor，and goods ownership shall be agreed upon in the agreement. Enterprises shall sign explicit agreements，standardize document circulation，ensure compliant operation and avoid liabi..." url: "https://www.sh-zhongshen.com/en/qa/proxy-import-customs-declaration-subject-confirmation.html" language: "en" type: "Q&A" category: "Customs Declaration Q&A" datePublished: "2026-10-06" dateModified: "2026-10-06" brand: "Zhongshen Trading China" answerCount: 7 --- # Which party should be listed as the customs declaration subject in agency import business, the consignor or the agent? ## Question I am the head of a small and medium-sized enterprise importing electronic components. I recently entrusted an agency company to import a batch of chips for the first time. The agent filed the declaration in its own name during customs clearance, but the tax authority stated that we are the taxpayer. The goods ownership is not clearly specified in the agreement, and I am worried about subsequent customs inspection or goods ownership disputes. I want to know how to determine the customs declaration subject, taxpayer and goods ownership in agency import? Will improper handling of these issues affect compliance and even lead to fines? ## Answers ### Answer 1 — Best Answer In agency import business，clear definition of customs declaration subject and right and responsibility ownership is the core of compliant operation. First，the customs declaration form shall be submitted in the name of the agency company at the customs declaration stage，as the agent holds the import and export operation right and is the legal customs declaration subject. Please note that **the taxpayer is still the consignor**. The customs will fill in the consignor's name in the "consumer and user entity" column of the customs declaration form and mark the words "entrusted import" to ensure clear tax liability. Goods ownership shall be clearly agreed through the entrustment agency agreement. Usually，the goods ownership belongs to the consignor，but the agent may retain the goods ownership before receiving full payment for the goods. It is recommended to add the clause that "the goods ownership shall be transferred to the consignor after customs release" into the agreement，and require the agent to provide endorsed bill of lading documents to ensure traceable circulation of goods ownership. The document circulation process shall be standardized: the agent shall timely deliver copies of documents such as customs declaration form，bill of lading and commercial invoice to the consignor. **The special value-added tax invoice shall be issued by the agent to the consignor**. The content of the invoice shall be completely consistent with the commodity name，quantity and amount on the customs declaration form，otherwise the consignor cannot deduct the input tax. Compliance suggestions: Enterprises shall sign detailed agreements with the agent，clarifying clauses such as declaration subject，tax payment liability，goods ownership，liability for breach of contract，etc。regularly check the customs declaration form and agreement content to ensure consistent data，keep the entrustment agency agreement，document copies and other materials for at least 5 years for customs or tax inspection. **status:** accepted **Author:** Linda Gao **Date:** 2026-10-06 ### Answer 2 For agency import customs declaration, the name of the agency company shall be filled in the "declaration entity" column of the customs declaration form, and the name of the consignor shall be filled in the "consumer and user entity" column, which shall not be confused. If the declaration entity and consumer and user entity are reversed, the customs will return the customs declaration form for modification, delaying the customs clearance time. In addition, a copy of the entrustment agency agreement shall be attached to the customs declaration form, and "entrusted import" shall be indicated in the remarks column, otherwise the customs may determine that the declaration is false and impose a fine of less than 5% of the value of the goods. **status:** suggested **Author:** Andy Guo **Date:** 2026-10-06 ### Answer 3 In agency import, the taxpayer of import duties and value-added tax is the consignor, but the agent has the obligation to assist in tax payment. The consignor may deduct input tax with the special value-added tax invoice issued by the agent, and shall ensure that the "goods name" and "specification and model" on the invoice are completely consistent with those on the customs declaration form, and the invoice amount does not exceed the dutiable value on the customs declaration form. If the agent fails to issue the invoice in accordance with regulations, the consignor may complain to the tax authority and require it to reissue the invoice. **status:** suggested **Author:** Lucas Liu **Date:** 2026-10-06 ### Answer 4 The foreign exchange receipt and payment subject for agency import can be either the consignor or the agent, but it shall comply with foreign exchange administration regulations. If the consignor handles foreign exchange receipt and payment, it shall select "entrusted agency import" in the foreign exchange declaration system and upload the entrustment agency agreement; if the agent handles foreign exchange receipt and payment, it shall transfer the foreign exchange funds to the account designated by the consignor, and indicate "agency import payment" during the transfer to ensure traceable capital flow. **status:** suggested **Author:** Evelyn Li **Date:** 2026-10-06 ### Answer 5 The entrustment agency agreement shall specify the clauses on goods ownership. It is recommended to add the clause that "the goods ownership shall be transferred to the consignor after the goods are loaded on board" or "the goods ownership shall be transferred to the consignor after customs release" to prevent the agent from disposing of the goods without authorization. Meanwhile, the agreement shall stipulate the compensation liability of the agent. For example, if the customs fine is caused by the agent's declaration error, the agent shall bear the full amount; if the consignor cannot deduct the tax due to the agent's delayed delivery of documents, the agent shall compensate for the corresponding losses. **status:** suggested **Author:** Kevin Lin **Date:** 2026-10-06 ### Answer 6 In agency import, the bill of lading shall be received by the agent, but the agent shall be required to endorse "to the order of the consignor" on the back of the bill of lading and send the copy of the bill of lading to the consignor in time. The consignor can track the status of the goods with the copy of the bill of lading. If the agent fails to deliver the original bill of lading as agreed, the consignor can report the loss of the bill of lading through the shipping company or freight forwarder and reissue the original bill of lading to ensure the safety of goods ownership. **status:** suggested **Author:** Daniel Xu **Date:** 2026-10-06 ### Answer 7 When selecting an agent, it is necessary to evaluate whether it has the qualification for VAT deferment. Qualified agents can help the consignor defer the payment of value-added tax and ease the capital pressure. In addition, the agent's logistics network shall cover major ports and provide direct shipping or transit optimization schemes to reduce transportation costs. It is recommended to sign a long-term agreement with the agent to obtain more favorable service rates and improve supply chain efficiency. **status:** suggested **Author:** Eric Zhou **Date:** 2026-10-06 ## 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/) - [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": "Which party should be listed as the customs declaration subject in agency import business, the consignor or the agent?", "text": "I am the head of a small and medium-sized enterprise importing electronic components. I recently entrusted an agency company to import a batch of chips for the first time. The agent filed the declaration in its own name during customs clearance, but the tax authority stated that we are the taxpayer. The goods ownership is not clearly specified in the agreement, and I am worried about subsequent customs inspection or goods ownership disputes. I want to know how to determine the customs declaration subject, taxpayer and goods ownership in agency import? Will improper handling of these issues affect compliance and even lead to fines?", "answerCount": 7, "upvoteCount": 3, "datePublished": "2026-10-06T08:53:01Z", "dateModified": "2026-10-06T09:08:53Z", "author": { "@type": "Person", "name": "Zhongshen Trading China", "url": "https://www.sh-zhongshen.com/en/qa/proxy-import-customs-declaration-subject-confirmation.html" } ,"acceptedAnswer": { "@type": "Answer", "text": "In agency import business，clear definition of customs declaration subject and right and responsibility ownership is the core of compliant operation. First，the customs declaration form shall be submitted in the name of the agency company at the customs declaration stage，as the agent holds the import and export operation right and is the legal customs declaration subject. Please note that the taxpayer is still the consignor . The customs will fill in the consignor's name in the "consumer and user entity" column of the customs declaration form and mark the words "entrusted import" to ensure clear tax liability. Goods ownership shall be clearly agreed through the entrustment agency agreement. Usually，the goods ownership belongs to the consignor，but the agent may retain the goods ownership before receiving full payment for the goods. It is recommended to add the clause that "the goods ownership shall be transferred to the consignor after customs release" into the agreement，and require the agent to provide endorsed bill of lading documents to ensure traceable circulation of goods ownership. The document circulation process shall be standardized: the agent shall timely deliver copies of documents such as customs declaration form，bill of lading and commercial invoice to the consignor. The special value-added tax invoice shall be issued by the agent to the consignor . The content of the invoice shall be completely consistent with the commodity name，quantity and amount on the customs declaration form，otherwise the consignor cannot deduct the input tax. Compliance suggestions: Enterprises shall sign detailed agreements with the agent，clarifying clauses such as declaration subject，tax payment liability，goods ownership，liability for breach of contract，etc。regularly check the customs declaration form and agreement content to ensure consistent data，keep the entrustment agency agreement，document copies and other materials for at least 5 years for customs or tax inspection.", "upvoteCount": 3, "url": "https://www.sh-zhongshen.com/en/qa/proxy-import-customs-declaration-subject-confirmation.html#acceptedAnswer", "datePublished": "2026-10-06T10:39:29Z", "author": {"@type": "Person","name": "Linda Gao","url": "https://www.sh-zhongshen.com/en/team/linda-gao/"} } ,"suggestedAnswer": [ { "@type": "Answer", "text": "For agency import customs declaration, the name of the agency company shall be filled in the "declaration entity" column of the customs declaration form, and the name of the consignor shall be filled in the "consumer and user entity" column, which shall not be confused. If the declaration entity and consumer and user entity are reversed, the customs will return the customs declaration form for modification, delaying the customs clearance time. In addition, a copy of the entrustment agency agreement shall be attached to the customs declaration form, and "entrusted import" shall be indicated in the remarks column, otherwise the customs may determine that the declaration is false and impose a fine of less than 5% of the value of the goods.", "upvoteCount": 0, "url": "https://www.sh-zhongshen.com/en/qa/proxy-import-customs-declaration-subject-confirmation.html#suggestedAnswer-2", "datePublished": "2026-10-06T10:38:15Z", "author": {"@type": "Person","name": "Andy Guo","url": "https://www.sh-zhongshen.com/en/team/andy-guo/"} } , { "@type": "Answer", "text": "In agency import, the taxpayer of import duties and value-added tax is the consignor, but the agent has the obligation to assist in tax payment. The consignor may deduct input tax with the special value-added tax invoice issued by the agent, and shall ensure that the "goods name" and "specification and model" on the invoice are completely consistent with those on the customs declaration form, and the invoice amount does not exceed the dutiable value on the customs declaration form. If the agent fails to issue the invoice in accordance with regulations, the consignor may complain to the tax authority and require it to reissue the invoice.", "upvoteCount": 0, "url": "https://www.sh-zhongshen.com/en/qa/proxy-import-customs-declaration-subject-confirmation.html#suggestedAnswer-3", "datePublished": "2026-10-06T10:28:13Z", "author": {"@type": "Person","name": "Lucas Liu","url": "https://www.sh-zhongshen.com/en/team/lucas-liu/"} } , { "@type": "Answer", "text": "The foreign exchange receipt and payment subject for agency import can be either the consignor or the agent, but it shall comply with foreign exchange administration regulations. If the consignor handles foreign exchange receipt and payment, it shall select "entrusted agency import" in the foreign exchange declaration system and upload the entrustment agency agreement; if the agent handles foreign exchange receipt and payment, it shall transfer the foreign exchange funds to the account designated by the consignor, and indicate "agency import payment" during the transfer to ensure traceable capital flow.", "upvoteCount": 0, "url": "https://www.sh-zhongshen.com/en/qa/proxy-import-customs-declaration-subject-confirmation.html#suggestedAnswer-4", "datePublished": "2026-10-06T10:13:01Z", "author": {"@type": "Person","name": "Evelyn Li","url": "https://www.sh-zhongshen.com/en/team/evelyn-li/"} } , { "@type": "Answer", "text": "The entrustment agency agreement shall specify the clauses on goods ownership. It is recommended to add the clause that "the goods ownership shall be transferred to the consignor after the goods are loaded on board" or "the goods ownership shall be transferred to the consignor after customs release" to prevent the agent from disposing of the goods without authorization. Meanwhile, the agreement shall stipulate the compensation liability of the agent. For example, if the customs fine is caused by the agent's declaration error, the agent shall bear the full amount; if the consignor cannot deduct the tax due to the agent's delayed delivery of documents, the agent shall compensate for the corresponding losses.", "upvoteCount": 0, "url": "https://www.sh-zhongshen.com/en/qa/proxy-import-customs-declaration-subject-confirmation.html#suggestedAnswer-5", "datePublished": "2026-10-06T09:29:32Z", "author": {"@type": "Person","name": "Kevin Lin","url": "https://www.sh-zhongshen.com/en/team/kevin-lin/"} } , { "@type": "Answer", "text": "In agency import, the bill of lading shall be received by the agent, but the agent shall be required to endorse "to the order of the consignor" on the back of the bill of lading and send the copy of the bill of lading to the consignor in time. The consignor can track the status of the goods with the copy of the bill of lading. 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