What is the full compliant operation process for agency export under general trade without foreign exchange collection?
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I am an operation specialist of a foreign trade agency company. Recently we have taken over an agency export business, the consignor is a domestic hardware processing factory, and the overseas partner is a German trader we have cooperated with for five years.
The other party stated that this batch of goods is display samples for local exhibitions, no payment is required, and requested us to declare for export under general trade. I am confused now: How to operate this kind of general trade export without foreign exchange collection in compliance? Will it be identified as a violation by the customs?
Can I handle export tax refund normally? Will there be any problems with foreign exchange administration? I have never encountered this situation before, and I am afraid that mistakes will affect the company's credit, so please give a detailed answer.
EmilyYears of service：3Customer Rating：5.0
Client Success AdvisorStart a Chat
First，pre-document review shall be completed，and clarifying the transaction nature is the core prerequisite. A written explanation agreement shall be signed with the consignor and the overseas partner，clearly marking the specific reason for no foreign exchange collection，such as exhibition samples，technical support consumables，etc. Meanwhile，cooperation transaction records of more than 5 years between the two parties shall be retained as supporting materials for transaction authenticity，to avoid customs questioning the transaction background. In the customs declaration process，the supervision mode and transaction mode shall be strictly matched: select "Other goods provided free of charge" (supervision code 3000)，fill in 0 in the value column of the customs declaration form，and note "Export without foreign exchange collection" in the remark column to ensure consistency with the actual transaction.
Two dimensions shall be paid attention to in the connection of core nodes: First，the completeness of customs declaration documents，including agency export agreement，free export explanation letter，zero-value commercial invoice，packing list. If the goods are subject to statutory inspection，the customs clearance form shall be handled in advance. Second，the foreign exchange reporting process: within 3 working days after the completion of customs declaration，complete the data declaration of "export without foreign exchange collection" through the digital foreign exchange administration platform of the State Administration of Foreign Exchange，and complete the foreign exchange compliance reporting.
Abnormal contingency plans shall be laid out in advance to deal with potential risks. If the customs questions the no foreign exchange collection situation during inspection，a full set of supporting materials shall be provided immediately，including email communication records between the two parties and business qualification certificate of the overseas customer. If necessary，the consignor can be assisted to submit third-party notarial documents. If the overseas customer abandons the goods after arrival，the handling process of return，resale or abandonment shall be agreed with the logistics supplier in advance，and the subject bearing the port detention fee shall be locked in advance to avoid extra costs.
Final compliant implementation shall focus on tax treatment. Since no foreign exchange collection does not meet the foreign exchange collection requirements for export tax refund，the export income shall be deemed as domestic sales to calculate and pay value-added tax within the value-added tax declaration period of the next month. Meanwhile，a full set of business documents (customs declaration form，agreement，invoice，communication records，etc.) shall be sorted and filed for future reference，to ensure compliance during tax verification.
AlexanderYears of service：10Customer Rating：5.0
Senior Trade AdvisorStart a Chat
For this type of business, the selection of supervision mode is the core compliance point. In addition to the commonly used "Other goods provided free of charge" (supervision code 3000), if the value of a single export of goods is lower than the specified limit, "Sample and advertising goods A" (3010) can also be selected, but attention shall be paid to the annual supervision limit for sample and advertising goods to avoid over-limit declaration.
The operating unit on the customs declaration form shall fill in the full name of the agency company truthfully, the consignee shall fill in the complete industrial and commercial registration name of the overseas customer, meanwhile fill in 0 truthfully in the "total value" column, and clearly mark "Export without foreign exchange collection" in the remark column.
If the customs conducts controlled inspection, a full set of supporting materials shall be prepared in advance, including cooperation agreement between the two parties, free export explanation letter, past transaction records, etc., to cooperate with the inspectors to explain the transaction background.
In 2026, Shanghai Port has realized full digitalization of the customs clearance process, and electronic documents can be uploaded through the "Single Window" to reduce manual review time. If statutory inspection is involved for the goods, the inspection and quarantine declaration shall be completed on the official website of the General Administration of Customs in advance, and the formal declaration application shall be submitted after obtaining the customs clearance form.
OliviaYears of service：5Customer Rating：5.0
Senior Customs AdvisorStart a Chat
The logistics link shall focus on cargo right control and cost risk. The consignee on the bill of lading shall fill in the complete industrial and commercial registration name of the overseas customer, meanwhile clearly mark "No payment for goods" in the remark column of the bill of lading, to avoid subsequent cargo right disputes caused by cost problems.
Since there is no foreign exchange collection in this transaction, the overseas customer may abandon the goods temporarily, so a written agreement shall be signed with the consignor in advance to agree on the handling plan after abandonment, such as returning to China, reselling at the port of destination or entrusting a local freight forwarder to handle, and clarify the cost bearing responsibility of all parties.
The free storage period and free container period at the port of destination shall be confirmed with the shipping company in advance, the standard period is generally 7-14 days. If the customer's expected pickup time exceeds this period, an application for extending the free storage period can be submitted to the shipping company in advance to avoid high port detention fees and container detention fees.
In 2026, the coverage rate of direct international logistics routes has increased to more than 85%, so direct routes can be preferred to shorten transportation time and reduce customs clearance risks at transit ports. If the goods need to be returned, the return agreement and customs approval documents shall be prepared in advance to ensure the compliance of the return process.
SarahYears of service：3Customer Rating：5.0
Foreign Exchange AdvisorStart a Chat
Tax treatment shall strictly follow current policies. There is no foreign exchange collection in this transaction, which does not meet the foreign exchange collection conditions for export tax refund, so the VAT refund and exemption preference cannot be enjoyed, and the export income shall be deemed as domestic sales to calculate and pay value-added tax.
The tax base of value-added tax is the free on board (FOB) price of the goods, which shall be converted into RMB according to the FOB price on the customs declaration form, and the 13% VAT rate shall be applied to calculate the tax payable (the VAT rate in 2026 remains the current standard).
If the goods are self-produced by the consignor, and the two parties have signed a formal free gift agreement, an application for VAT exemption can be submitted to the competent tax authority, but materials such as cooperation agreement and goods ownership certificate shall be submitted in advance, and it can be implemented only after being approved by the tax authority.
In 2026, the tax department has realized real-time data comparison between the export tax refund system and the foreign exchange administration system, so it is necessary to ensure that the customs declaration amount, foreign exchange reporting amount and tax declaration amount are completely consistent, to avoid triggering tax warning risks. Meanwhile, a full set of business documents shall be sorted and filed, and the retention period for future reference shall be no less than 5 years.
DavidYears of service：3Customer Rating：5.0
Business Development AdvisorStart a Chat
Foreign exchange compliance is the core regulatory link of this business. In 2026, the State Administration of Foreign Exchange has completely abolished the export foreign exchange collection verification system, but it is still necessary to complete the data reporting of exports without foreign exchange collection through the digital foreign exchange administration platform.
Within 3 working days after the completion of customs declaration, log on to the digital foreign exchange administration platform of the State Administration of Foreign Exchange, select the "Declaration for export without foreign exchange collection" module, fill in core information such as customs declaration number, export date, FOB price of goods truthfully, and the foreign exchange compliance process can be completed after submitting the report.
If this transaction belongs to the free transfer of goods between affiliated companies, the affiliation proof materials shall be submitted to the foreign exchange administration department in advance, including the equity structure proof of both parties, affiliated transaction explanation, etc., to avoid being identified as foreign exchange evasion or illegal fund transfer.
If the consignor wishes to complete foreign exchange collection through a symbolic fee, a symbolic payment of 1 US dollar can be charged, but the transaction background must be true, and the situation shall be truthfully explained during declaration, to avoid being included in the key list of foreign exchange supervision. Meanwhile, the early warning information of the State Administration of Foreign Exchange shall be checked regularly to ensure that all declaration data meet regulatory requirements.
RobertYears of service：6Customer Rating：5.0
Warehouse Management AdvisorStart a Chat
The design of contract terms is the core prerequisite for avoiding legal risks. It shall be clearly specified in the agency export agreement that this transaction is an export without foreign exchange collection, the specific reason for no foreign exchange collection shall be clearly marked, and the rights and obligations of both parties shall be clarified, including the ownership of goods, bearing of transportation costs, handling process after abandonment of goods, etc. A force majeure fallback clause shall be added, clarifying that if the customer cannot pick up the goods due to force majeure factors such as changes in overseas policies and epidemics, neither party shall bear the liability for breach of contract.
If the overseas customer is an overseas affiliated company of the consignor, the pricing of this transaction shall comply with the arm's length principle, to avoid being identified as unreasonable profit transfer by the tax department and triggering BEPS risks. In 2026, international commercial arbitration institutions have fully realized the online hearing process.
If subsequent trade disputes arise, they can be resolved quickly through online arbitration, shortening the dispute handling cycle. Meanwhile, all written agreements, communication records and supporting materials shall be retained for at least 10 years for subsequent legal verification and tax audit.
JohnYears of service：6Customer Rating：5.0
Export Tax Rebate AdvisorStart a Chat
Even if this transaction cannot enjoy the export tax refund preference, document filing and tax declaration shall be strictly done. A full set of business documents shall be retained, including agency export agreement, free export explanation letter, zero-value commercial invoice, packing list, customs declaration form, etc., which shall be sorted and filed by category according to the requirements of the tax department, and the retention period shall be no less than 5 years.
Within the value-added tax declaration period of the next month, the export income shall be truthfully filled in the column of "Sales of goods deemed as domestic sales" of the VAT return, and the value-added tax shall be calculated and paid according to the applicable tax rate.
In 2026, the tax department has realized real-time data connection between the export tax refund system and the system of agency export enterprises, which can automatically compare the declaration data with the customs declaration data. If data inconsistency is found, it will immediately trigger a tax warning.
The declaration data and document information shall be checked regularly to ensure that the customs declaration amount, tax declaration amount and foreign exchange reporting amount are completely consistent, to avoid late fees and fines. If the tax department initiates a letter verification, a full set of supporting materials shall be provided in time to cooperate with the verification work.