Does a company need a valid import and export operating right qualification when entrusting customs brokerage
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I am a small and micro enterprise in the early stage of cross-border trade, mainly engaged in cross-border e-commerce B2B export of daily small commodities. This is my first attempt at full container load ocean shipment; previously, I only used scattered freight forwarders for parcel express services, and now I need to complete the formal customs clearance process.
I have not yet had time to apply for import and export operating rights. I heard from peers that without this certificate, I cannot declare customs myself, but the freight forwarder I contacted said they can act as an agent for customs declaration. I am now confused: do I need to obtain the qualification myself, or is it enough to just find an agency?
In addition, if I do not have this qualification, will my goods be detained by customs, or will it affect subsequent tax refunds? Can you explain in detail the relationship between customs brokerage and import and export operating rights, and is there a fast compliance method for my small company?
CharlotteYears of service：4Customer Rating：5.0
Currency Exchange AdvisorStart a Chat
First clarify the core conclusion: Customs brokerage does not mandate the entrusting party to hold import and export operating rights，the compliance qualification of the customs declaration entity is the core threshold. After the 2026 customs integrated clearance reform，the qualification review of customs brokerage focuses on the declaration entity itself，and the entrusting party only needs to provide valid proof of cargo ownership and trade background materials.
For entrusting parties without import and export operating rights，adjust operations by scenario: For general trade exports，the customs brokerage company can act as the filing entity of the consignee/consignor，fill in its own qualification in the "Consignee/Consignor" column of the customs declaration form，and note the actual cargo owner in the "Remarks" column，For cross-border e-commerce B2B exports，relying on the 9610/9710 regulatory codes，the agent can complete the customs declaration filing uniformly，and the entrusting party does not need to apply for import and export operating rights in advance.
Two types of risks need attention: First，if the entrusting party needs to apply for export tax refund later，it must confirm that it has completed the import and export operating rights filing and tax refund qualification registration before customs declaration，otherwise it cannot enjoy the tax refund benefits，Second，if customs questions the cargo ownership，provide supporting materials such as the entrustment agency agreement and purchase invoice in time to avoid detention or delay at the port. The filling of the consignee/consignor in the customs declaration form must strictly follow the rules of Customs Announcement No.12 of 2026，and random filling is strictly prohibited.
If you are a small and micro enterprise in the early stage，you can choose to cooperate with a customs brokerage company with dual-header customs clearance qualifications，complete the first customs declaration without applying for import and export operating rights yourself，and supplement relevant qualifications after business stabilizes. The overall process only takes 3-5 working days to complete the whole process of customs brokerage. If you need to apply for tax refund，clarify the actual tax refund entity at the time of customs declaration，and ensure the consistency of the four streams (contract，invoice，logistics，capital flow) to avoid problems in subsequent tax inspections.
DanielYears of service：8Customer Rating：5.0
Legal AdvisorStart a Chat
For entrusting parties without import and export operating rights in customs brokerage scenarios, focus on the logical consistency of the customs declaration form. After the 2026 customs valuation system is upgraded, it will automatically compare the matching degree of consignee/consignor, producer/seller, and cargo ownership proof. If the entrusting party does not have import and export operating rights, specify the cargo ownership transfer node in the agency agreement, and mark "Entrusted customs brokerage, actual shipper is [Entrusting Party Name]" in the remarks column of the customs declaration form to avoid abnormalities in the valuation link.
If it involves cross-border e-commerce B2B exports, ensure that the list data under the 9610 regulatory code is consistent with the customs declaration form data, otherwise it will trigger customs inspection. If the consignee/consignor is mistakenly filled as the entrusting party, apply for deletion and re-declaration in time, submit the agency qualification proof and the entrusting party's statement of no import and export operating rights to avoid demurrage fees.
RobertYears of service：6Customer Rating：5.0
Warehouse Management AdvisorStart a Chat
For entrusting parties without import and export operating rights in customs brokerage, adjust logistics terms appropriately. It is recommended to select ports with an extended free demurrage period of up to 14 days to avoid demurrage fees caused by delays in qualification review. In addition, the consignee of the bill of lading should be filled in as the brokerage company, and after customs declaration is completed, it should be transferred to the entrusting party through endorsement to ensure compliance of cargo ownership transfer.
For full container load shipment, you can choose the integrated clearance channel at Shanghai Yangshan Port, relying on the 2026 "Fast Clearance" mechanism, which can shorten customs clearance time by more than 30%. At the same time, confirm the cargo ownership control process of the customs brokerage with the freight forwarder in advance to avoid cargo ownership disputes.
AlexanderYears of service：10Customer Rating：5.0
Senior Trade AdvisorStart a Chat
For entrusting parties without import and export operating rights in customs brokerage, pay attention to cross-border tax compliance. If the brokerage company collects payment on behalf, clearly specify the amount and purpose of the collection and payment in the agency agreement to avoid being identified as related party transactions.
In addition, if you need to apply for export tax refund later, ensure the consistency of the four streams; the brokerage company needs to provide supporting documents for collection and payment, and the entrusting party needs to complete online foreign exchange verification within 30 days after receiving the payment. The State Administration of Foreign Exchange has simplified this process in 2026, and it can be directly handled through the electronic tax bureau. If involving VAT deferral, confirm the VAT qualification of the brokerage company in advance to ensure that the deferral process complies with the EU's 2026 tax regulations.
SarahYears of service：3Customer Rating：5.0
Foreign Exchange AdvisorStart a Chat
For entrusting parties without import and export operating rights engaged in cross-border trade, comply with the 2026 cross-border payment and collection regulations. It is recommended to use the CIPS Cross-border RMB Payment System for settlement, avoiding foreign exchange conversion and thus exchange rate risks.
At the same time, ensure that the amount of each payment and collection is consistent with the customs declaration amount; if there is a difference, provide a reasonable explanation (such as deduction of freight and insurance premiums). In addition, the use of offshore accounts must comply with the regulatory requirements of the People's Bank of China to avoid being identified as abnormal accounts. You can settle through the compliant accounts of the brokerage company to reduce compliance risks.
OliviaYears of service：5Customer Rating：5.0
Senior Customs AdvisorStart a Chat
For entrusting parties without import and export operating rights in customs brokerage, sign a formal entrustment agency agreement to clarify the rights and obligations of both parties. The agreement should specify terms such as cargo ownership, customs declaration responsibilities, tax refund responsibilities, and the burden of demurrage losses to avoid subsequent disputes.
If involving intellectual property protection, complete customs filing in advance to ensure that the goods will not be seized during customs clearance. If a cargo ownership dispute occurs, you can apply for cargo ownership confirmation to customs through the entrustment agency agreement, and at the same time, protect your rights and interests through legal channels. Customs has opened an online cargo ownership dispute processing channel in 2026, which can shorten the processing cycle.
SophiaYears of service：7Customer Rating：5.0
Senior Customs AdvisorStart a Chat
If the goods of entrusting parties without import and export operating rights are selected for customs inspection, prepare in advance. First, ensure that the packaging of the goods is consistent with the declaration information to avoid being required to open the container for inspection due to packaging inconsistencies. Secondly, bring supporting materials such as the entrustment agency agreement, purchase invoice, and packing list to explain the cargo ownership to the inspectors.
For general goods, prepare the manufacturer's certificate of the goods in advance; for dangerous goods, provide the UN packaging certificate and MSDS report in advance to meet the on-site inspection requirements. In addition, you can ask the on-site inspection specialist of the brokerage company to accompany you to assist in communicating and handling inspection issues, improving inspection efficiency.
WilliamYears of service：10Customer Rating：5.0
International Logistics AdvisorStart a Chat
If the goods of entrusting parties without import and export operating rights are general goods, ensure that the packaging meets international transportation standards to avoid being seized by customs due to packaging problems during customs clearance. For fragile goods, use cushioning materials for reinforcement, and mark fragile signs on the packaging.
For dangerous goods, complete the UN dangerous goods packaging identification and prepare the MSDS report in advance to ensure that the packaging meets IMDG regulations. In addition, paste the correct dangerous goods signs on the packaging to avoid being required to rectify due to incorrect signs and generate additional costs. The International Maritime Organization has updated the dangerous goods packaging standards in 2026, and it is necessary to ensure that the packaging meets the latest requirements.
JohnYears of service：6Customer Rating：5.0
Export Tax Rebate AdvisorStart a Chat
If entrusting parties without import and export operating rights need to apply for export tax refund, complete the import and export operating rights filing and tax refund qualification registration in advance. When declaring customs, mark "Actual tax refund entity is [Entrusting Party Name]" in the remarks column of the customs declaration form, and ensure that the collection voucher is consistent with the customs declaration amount.
In addition, complete the document filing work, including the purchase contract, packing list, customs declaration form, collection voucher, etc. The tax authorities have realized online verification of the tax refund system in 2026, and you can submit filing materials through the electronic tax bureau without offline submission to improve tax refund efficiency. If the tax authorities initiate a letter check, provide relevant supporting materials in time to avoid tax refund delays.
EmilyYears of service：3Customer Rating：5.0
Client Success AdvisorStart a Chat
Entrusting parties without import and export operating rights can optimize the supply chain structure through the customs brokerage model. It is recommended to cooperate with a brokerage company with cross-port linkage capabilities to achieve integrated clearance across ports and reduce logistics costs.
If the business volume is stable, you can consider applying for import and export operating rights to realize independent customs declaration and collection and improve the autonomy of the supply chain. In addition, you can use the CIF trade term, and the brokerage company is responsible for logistics and customs declaration to reduce your own operation costs.
At the same time, you can optimize inventory and logistics paths through supply chain planning models to reduce overall operation costs. Multiple digital supply chain tools have been launched in 2026 to help enterprises achieve cost calculation.