I.Agency export,Who should bear the legal responsibility?

According to the latest revised "Customs Administrative Penalty Implementation Regulations" in 2025, the export declaration entity is responsible for the authenticity of the customs declaration form.Primary legal liability。Under the agency export model, when the following circumstances occur:

• Incorrect HS code classification leads to tax refund disputes
• False information on the certificate of origin triggered an anti-dumping investigation.
• The difference between the declared amount and the received amount exceeds 5%.

The actual cargo owner enterprise may faceAdministrative Penalty Joint LiabilityIn 2023, a lighting company in Ningbo was required by customs to pay back taxes for three years due to an agency firm's false reporting of FOB prices.Export tax refundThe difference and a fine of 1.27 million yuan.

II. How Can Agency Export Trigger Tax Audit Risks?

In the key monitoring of "export by purchasing foreign exchange" by tax authorities in 2025, the agency export model is involved.The third-party information does not match.Typical characteristics:

• The VAT invoice title does not match the consignor on the customs declaration.
• The recipient of foreign exchange is different from the operating entity.
• Logistics documents and customs declaration information time mismatch

A Guangzhou-based garment foreign trade company in 2024 was found to have used falsely issued input invoices for its export agency services, resulting not only in the loss of already refunded taxes but also requiring the company to make up for a 17% value-added tax (VAT) shortfall.

III. Why does export agency lead to loss of control over business operations?

Our real-world case studies have shown that the agency export model presentsTriple out-of-control risks:

• Customer information leakage: Agents establish their own businesses after obtaining end-buyer information.
• Difficulty in capital turnover: The bad debt rate caused by agents misappropriating payments reached 8.7%.
• Quality traceability failure: In the 2024 EU RAPEX notification cases, 32% of agency-exported products could not trace back to the actual manufacturers.

IV. Can Agency Export Truly Reduce Compliance Costs?

Behind the seemingly low 1-2% service fee rate, businesses may actually bearHidden compliance costs:

• Document review cost: An average of 3.5 additional hours of manual verification per shipment.
• Logistics tracking cost: Additional purchase of in-transit cargo insurance is required.
• Emergency handling costs: In 2025, at the Shanghai Port, the demurrage fees for agency exports in abnormal inspection cases were 40% higher than those for self-operated exports.

V. How can agency export harm a company's credit rating?

According to the People's Bank of China's 2025 Cross-Border Trade Enterprise Credit Evaluation System, export agency may triggerThree credit score deductions:

• The authenticity of the trade is in doubt, leading to restricted financing.
• Multi-party transactions reduce Customs AEO certification scores.
• Abnormal foreign exchange receipts and payments affect bank credit lines.

A Shenzhen-based electronics company, due to its long-term reliance on export agency services, was required by the bank to provide an additional 30% collateral when applying for a supply chain loan in 2024.