Who is responsible for foreign exchange collection in agency export?
Importing from China?
Need help with sourcing, customs or shipping?
Your China Import Partner
Reliable sourcing and import agency services.
I am the person in charge of a small trading company engaged in the export of consumer electronics. Last month, I signed an export agreement with an agency company in Shanghai, agreeing that they would be responsible for customs declaration and tax refund. But recently, the agency proposed that they would collect foreign exchange; however, the bank notified that the foreign exchange collection subject was inconsistent with the subject of the customs declaration form, and the collection had been returned twice. Now the goods have been cleared at the Singapore Port.
If foreign exchange collection is delayed for more than 7 days, it may affect the tax refund declaration. I am also worried about the new verification requirements of SAFE for the foreign exchange collection subject in 2026. I want to know which party is compliant to collect foreign exchange in agency export? How to operate to avoid exchange difference losses and tax refund overdues?
EllaYears of service：10Customer Rating：5.0
Senior Financial AdvisorStart a Chat
The determination of the foreign exchange collection subject in agency export must closely align with the joint regulatory requirements of SAFE and STA in 2026，with the core logic being "consistent documents + subject binding". It can be broken down and implemented along the entire chain as follows:
First is pre-audit: The agency agreement must clearly specify the consistency between the foreign exchange collection subject and the tax refund subject - SAFE requires in 2026 that the agreement must be sealed with official chops of both parties，and stipulate that "if the agency collects foreign exchange，the funds shall be transferred within 3 working days". At the same time，the "domestic consignor" on the customs declaration form must match the foreign exchange collection subject (if agency collection is selected，the principal's "Foreign Exchange Collection Authorization Letter" must be submitted synchronously，including the goods value，currency，and account information，and filed in the foreign exchange system).
Connection of core nodes: 1. Check before customs declaration: if the domestic consignor on the customs declaration form is the principal，the foreign exchange collection subject must be the principal，if it is the agency，the authorization letter shall be submitted synchronously with the customs declaration，2. During foreign exchange collection: the bank shall verify the consistency between the foreign exchange collection subject，the customs declaration form，and the agreement，and an additional authorization letter shall be provided for agency collection，3. Connection with tax refund: STA requires in 2026 that the foreign exchange collection vouchers must be consistent with the subjects of the customs declaration form and invoices，and the agency shall supplement the "Foreign Exchange Transfer Certificate" (stamped by the bank + transfer details).
Exception plan: if it is returned due to wrong foreign exchange collection subject，the "Application for Correction of Subject of Customs Declaration Form" shall be submitted within 10 working days (with the agreement and authorization letter attached)，and the customs shall update the data after approval to avoid affecting the 90-day tax refund declaration deadline，if the exchange difference exceeds 3% (adjusted value in 2026)，a difference explanation (including contract terms) shall be provided.
Final suggestions: Give priority to the principal for foreign exchange collection to avoid transfer risks，if the agency collects foreign exchange，the exchange difference bearer shall be specified in the agreement (settled at the mid-price on the day of foreign exchange collection)，and the authorization letter shall be filed in advance in the foreign exchange system.
OliviaYears of service：5Customer Rating：5.0
Senior Customs AdvisorStart a Chat
Announcement No.12 of the General Administration of Customs in 2026 clarifies that the "domestic consignor" on the customs declaration form for agency export can be selected as the principal or the agency, but must be consistent with the foreign exchange collection subject. If the principal is filled in the customs declaration form, the foreign exchange collection subject must be the principal; if it is the agency, the principal's "Foreign Exchange Collection Authorization Letter" (including goods value, currency, account, and double chops) must be submitted synchronously.
If the subjects are inconsistent, the customs declaration form will be marked as "to be verified", which will affect the tax refund declaration. If an error has occurred, the "Correction Application" shall be submitted within 15 working days (with the agreement and authorization letter attached), and the customs shall update the data after approval to avoid late declaration fee.
AlexanderYears of service：10Customer Rating：5.0
Senior Trade AdvisorStart a Chat
Foreign exchange collection in agency export needs to be connected with the bill of lading: under FOB terms, the notify party of the bill of lading can be the agency, but it must be noted that "delivery of goods is based on the principal's authorization letter"; under CIF terms, the logistics fee shall be paid by the foreign exchange collection subject and can be deducted first after collection.
The Singapore Port requirements in 2026 stipulate that the container detention fee caused by foreign exchange collection delay shall be borne by the foreign exchange collection subject, and the agreement shall specify the responsible party. If a transshipment plan is adopted, the verification requirements of the transshipment port for the foreign exchange collection subject shall be confirmed to avoid loss of cargo ownership.
CharlotteYears of service：4Customer Rating：5.0
Currency Exchange AdvisorStart a Chat
Announcement No.5 of STA in 2026 requires that the tax refund foreign exchange collection vouchers must be consistent with the subjects of the customs declaration form and invoices. For agency collection, the agency shall provide the "Foreign Exchange Transfer Certificate" (stamped by the bank + transfer details) and submit the "Agency Export Tax Refund Certificate" (with double chops).
If the difference between the foreign exchange collection amount and the customs declaration amount exceeds 3%, a difference explanation (including contract terms) shall be provided to avoid being identified as false export. Cross-border related transactions shall comply with the BEPS Action 7 requirements, and the foreign exchange collection price shall be consistent with the arm's length price.
RobertYears of service：6Customer Rating：5.0
Warehouse Management AdvisorStart a Chat
SAFE requires in 2026 that foreign exchange collection in agency export must be conducted through CIPS or SWIFT, and direct collection from offshore accounts is prohibited (except for overseas principals). For agency collection, the agency shall file the "Foreign Exchange Collection Authorization Letter" in the foreign exchange monitoring system, and can only collect foreign exchange after filing.
The funds shall be transferred to the principal within 3 working days after collection, marked as "agency collection transfer" to avoid fund detention. Non-US dollar collection shall be settled at the mid-price on the day of collection, and exchange difference losses shall be borne as agreed in the agreement.
EmilyYears of service：3Customer Rating：5.0
Client Success AdvisorStart a Chat
The agency agreement must specify the foreign exchange collection subject terms: 1. Subject selection (principal/agency); 2.
Delay liability (daily penalty ≤0.05%); 3. Exchange difference bearer; 4. Cargo ownership transfer conditions (transferred after collection completion).
After the revision of the International Trade Law in 2026, the foreign exchange collection subject change shall be notified to the other party 7 working days in advance, otherwise the loss shall be borne. If the delay is caused by force majeure, a bank foreign exchange control certificate shall be provided to exempt part of the liability.
DanielYears of service：8Customer Rating：5.0
Legal AdvisorStart a Chat
Tax refund audit requirements in 2026 require "four flows consistency": contract (agency agreement), invoice, goods flow (bill of lading/loading list), and capital flow (foreign exchange collection voucher/transfer certificate).
For agency collection, the agency shall file: agreement, authorization letter, foreign exchange collection voucher, transfer certificate, invoice, and customs declaration form. Tax inquiry shall be replied with original documents within 10 working days, and foreign exchange collection delay can apply for an extension (maximum 30 days) with bank return voucher.
SarahYears of service：3Customer Rating：5.0
Foreign Exchange AdvisorStart a Chat
Foreign exchange collection subject selection combined with trade terms: select the principal for FOB to avoid transfer costs; select the agency for CIF to deduct logistics fees first and reduce capital occupation.
Due to the high RMB fluctuation in 2026, the agreement can stipulate "exchange rate locked at the mid-price on the signing date". Exports from RCEP member countries can use origin rules to reduce tariffs, and the foreign exchange collection subject enjoys foreign exchange convenience (no need to file the authorization letter).