---
title: "Can manufacturing enterprises with self-operated export qualifications still entrust an agency company to handle the entire export process?"
description: "Enterprises with self-operated export qualifications often face the dilemma of high self-operated costs and low customs clearance efficiency due to limited overseas channels，cumbersome tax refund procedures or insufficient human resource allocation. Choosing compliant agency export can rely on the full-link operations of professional institutions，avoid process loopholes in self-operation，safeguard tax refund rights，reduce logistics and exchange costs through the agency's resources，and achieve ef..."
url: "https://www.sh-zhongshen.com/en/qa/self-operated-export-qualified-manufacturers-entrust-agent-export-services.html"
language: "en"
type: "Q&A"
category: "Export Agency Q&A"
datePublished: "2026-07-04"
dateModified: "2026-07-04"
brand: "Zhongshen Trading China"
answerCount: 8
---

# Can manufacturing enterprises with self-operated export qualifications still entrust an agency company to handle the entire export process?

## Question

 I am the person in charge of a hardware manufacturing enterprise in Shanghai with self-operated export qualifications. I just signed a bulk order worth 1.2 million US dollars with a German client last week, and originally planned to handle the export by ourselves. However, the core employee responsible for customs declaration and tax refund suddenly resigned, and the newly hired specialist has not yet familiarized themselves with the customs clearance rules of European customs. Previously, during our self-operated export, we had goods detained in the port for 3 days due to inconsistent documents, and paid nearly 150,000 yuan in detention fees and customer liquidated damages. Now I am particularly anxious: I am afraid of making similar mistakes again, and I am not sure whether enterprises with export qualifications can entrust an agency company to handle the entire export process? Will it be considered a violation by the customs? Will it also affect our right to apply for export tax refunds? 

## Answers
                            
### Answer 1 — Best Answer

Many enterprises with export qualifications have misunderstandings，thinking that self-operated qualifications and agency export are mutually exclusive，or that they can operate casually by finding an agency. This is a common compliance blind spot in the industry. If you entrust export without completing the agency filing as required，it will cause a conflict between the customs declaration subject and the enterprise's self-operated qualification filing information，triggering customs control. At best，the goods will be detained in the port for 3-7 days. According to the 2026 Shanghai Port standard of 120 USD per day for 40-foot container detention fees，7 days will cost nearly 6,000 RMB，and you also need to pay the customer a liquidated damages of about 1% of the order value. At worst，the goods will be detained for inspection，the enterprise's customs credit rating will be downgraded from general credit to dishonest，subsequent self-operated exports will be under key customs control，and even export tax refunds will be under indefinite investigation，directly affecting the enterprise's cash flow.

The core of physical risk isolation is to complete **dual-subject compliance filing**: In 2026，the General Administration of Customs clearly requires that qualified enterprises entrusting agency export must complete the dual-subject filing for agency export on the "Single Window" in advance，clarify the customs declaration authority of the agency company and the ownership of the enterprise's self-operated qualifications，and ensure that the operating units on customs declarations and manifests are consistent with the filing subjects，so as to fundamentally avoid subject conflicts.

Exclusive loss prevention tip: Choose an institution with more than 20 years of agency experience，adopt the **separate custody of documents** mode，separate and store customs declaration documents and tax refund documents to ensure that the tax refund rights fully belong to the entrusting enterprise. At the same time，the agency's dedicated compliance specialist will follow up on customs control alerts throughout the process. Once an abnormality occurs，submit the "Compliance Explanation Letter" and supporting materials within 24 hours，and complete the lifting of customs control within 12 hours at the fastest speed to avoid expanding detention losses.

**status:** accepted
**Author:** Kevin Lin
**Date:** 2026-07-04

### Answer 2

The "Regulations on Supervision of Agency Export Business" issued by the General Administration of Customs in 2026 clearly states that enterprises with self-operated export qualifications may entrust agency export, but must complete the dual-subject filing before customs declaration. When declaring customs, you need to submit the "Agency Export Agreement", a copy of the enterprise's self-operated qualification certificate, and the customs declaration power of attorney from the agency company. If complete materials are not submitted, the customs will directly return the declaration, causing the goods to fail to pass customs normally.

If a declaration return occurs, you need to supplement the complete filing materials within 24 hours, and submit the "Subject Compliance Explanation Letter" at the same time to avoid goods detention in the port. In addition, the "operating unit" on the customs declaration form must be filled with the entrusting party (qualified enterprise), and the "declaration unit" must be filled with the agency company. The two cannot be confused, otherwise it will trigger customs valuation control, and you need to additionally submit transaction statements, purchase contracts and other materials, delaying customs clearance time.

**status:** suggested
**Author:** Michael Zhang
**Date:** 2026-07-04

### Answer 3

When enterprises with export qualifications entrust agency export, control of cargo rights is the core. In 2026, the international logistics market has tight shipping capacity, especially on European routes. If the agency company does not adopt the "telex release bill of lading endorsement" mode as agreed, it will lead to out of control of cargo right transfer, and the risk of goods being picked up without a bill of lading will occur. In addition, when doing agency export, you need to confirm the logistics path in advance.

If the freight forwarder commonly used by the enterprise for self-operated export is different from that of the agency company, you need to connect the manifest information in advance to avoid customs detention caused by inconsistent manifest and customs declaration information. For European routes, it is recommended to use the direct shipping route of the agency company, which saves 3-5 days compared with the self-operated transit route. At the same time, the agency company can apply for the "pre-customs clearance manifest filing" service launched by the customs in 2026 to complete the manifest review in advance and reduce customs clearance time.

**status:** suggested
**Author:** Cindy Chen
**Date:** 2026-07-04

### Answer 4

When enterprises with export qualifications entrust agency export, they can enjoy the same VAT refund rights as self-operated export, but need to pay attention to the calculation of the tax base. In 2026, the State Taxation Administration stipulates that the tax refund base for agency export shall be based on the actual purchase cost of the entrusting party, rather than the invoiced amount of the agency company.

If the agency export mode is adopted, the enterprise can apply for "VAT deferred declaration", defer the VAT that needs to be paid at the time of export until after the goods are sold to overseas customers, and relieve the cash flow pressure. In addition, if the enterprise has cross-border related party transactions, it needs to ensure that the transaction pricing of agency export complies with the arm's length principle, avoid being identified as profit transfer by the tax authority, trigger BEPS investigation, and affect the enterprise's tax credit rating.

**status:** suggested
**Author:** Eric Zhou
**Date:** 2026-07-04

### Answer 5

When enterprises with export qualifications entrust agency export, the receipt and payment of foreign exchange must comply with the "Cross-border Receipt and Payment Compliance Rules" issued by the State Administration of Foreign Exchange in 2026. Two modes are allowed: "entrusting party receives foreign exchange" or "agency receives foreign exchange and transfers it", and third-party foreign exchange receipt is prohibited.

If the agency receives foreign exchange and transfers it, the foreign exchange must be transferred to the entrusting party's foreign exchange account within 3 working days after receiving the foreign exchange, and the "Agency Receipt Explanation Letter" must be submitted to the State Administration of Foreign Exchange for filing to avoid being identified as illegal foreign exchange settlement. In addition, the "59 field" of the SWIFT message must be filled with the full name and account number of the entrusting party.

If the information of the agency company is filled in, it will trigger the compliance inspection of the State Administration of Foreign Exchange, resulting in delayed foreign exchange settlement. It is recommended to use the CIPS RMB cross-border payment system for foreign exchange receipt and payment, which can enjoy the "Compliant Receipt and Payment Green Channel" launched by the State Administration of Foreign Exchange in 2026 to reduce inspection time.

**status:** suggested
**Author:** Daniel Xu
**Date:** 2026-07-04

### Answer 6

When enterprises with export qualifications entrust agency export, they need to sign a standardized "Agency Export Agreement" to clarify the rights and obligations of both parties, especially clauses such as cargo right transfer, document ownership, and liability for breach of contract. In 2026, common agency disputes in the foreign trade industry are mostly caused by the failure to clarify the "document ownership" in the agreement, resulting in the agency company withholding customs declarations, tax refund documents and other materials, affecting the enterprise's tax refund application.

In addition, if overseas customers adopt letter of credit payment, it is necessary to clarify in the agreement that the agency company needs to cooperate in reviewing the soft clauses of the letter of credit, such as the soft clause "the customer inspection certificate must be signed by the personnel designated by the overseas customer", to avoid refusal of payment due to discrepancies. It is recommended to add a "Document Custody Clause" to the agreement, clarifying that the agency company is only responsible for keeping the documents, and the ownership belongs to the entrusting party. If the agency company withholds the documents, it shall bear a liquidated damages of 0.05% per day.

**status:** suggested
**Author:** Victor Sun
**Date:** 2026-07-04

### Answer 7

When enterprises with export qualifications entrust agency export, they need to ensure "four flows consistency", that is, the subjects of contract flow, cargo flow, capital flow and invoice flow are consistent. In 2026, the key focus of the State Taxation Administration's export tax refund inspection is "four flows consistency". If during agency export, the contract flow is signed by the agency company and overseas customers, the cargo flow is shipped by the entrusting party, the capital flow is paid by overseas customers to the agency company, and the invoice flow is issued by the entrusting party to the agency company, it will be identified as "four flows inconsistency", and the enterprise will not be able to apply for export tax refunds.

It is recommended to adopt the mode of "the entrusting party directly signs the contract with overseas customers", and the agency company only acts as the entrusted party for customs declaration and logistics to ensure four flows consistency. At the same time, it is necessary to submit the "Certificate of Agency Export Goods" when applying for tax refund, and the agency company shall file it in the tax system to avoid rejection of the tax refund application.

**status:** suggested
**Author:** Jason Wu
**Date:** 2026-07-04

### Answer 8

When enterprises with export qualifications entrust agency export, they can reduce comprehensive costs by optimizing the supply chain structure. In 2026, the core costs of the foreign trade industry are logistics costs, exchange costs and labor costs.

Agency export can use the scale advantage of the agency company to get a logistics discount of 10%-15% lower than self-operated export. At the same time, the exchange team of the agency company can lock the forward exchange rate in 2026 to avoid exchange losses caused by RMB appreciation.

In addition, agency export can convert the fixed labor costs of the enterprise's self-operated export department into service fees charged per order, which is 30%-40% lower than the self-operated labor costs. It is recommended to adopt the mode of "core business self-operated, non-core business outsourced", entrust non-core businesses such as customs declaration, logistics and tax refund to the agency company, focus on production and overseas channel expansion, and improve core competitiveness.

**status:** suggested
**Author:** Evelyn Li
**Date:** 2026-07-04

## Related Categories
- [Import Agency Q&A](https://www.sh-zhongshen.com/en/qa/cat-import-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/)
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