Key Compliance Points to Note for Agent Customs Declaration Under the "Who Exports, Who Collects Foreign Exchange" Rule
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I am the person in charge of a foreign trade factory. In 2026, we recently expanded to the Southeast Asian market, and recently we have a batch of goods entrusted to an agent customs declaration company for export procedures at Shanghai Port, but the customer requires payment to be directly transferred to our domestic offshore account, while the agent customs declaration company’s head office is their own company.
Now I am worried that this does not comply with the "Who Exports, Who Collects Foreign Exchange" rule, fearing customs verification and affecting subsequent export tax refunds. Previously, we did customs declaration and foreign exchange collection by ourselves; this is the first time we have worked with an agent and encountered this problem.
I don’t know whether the foreign exchange collection subject must be consistent with the shipper on the customs declaration form when doing agent customs declaration. If inconsistent, how to adjust operations to meet compliance requirements without delaying delivery and fund collection?
DavidYears of service：3Customer Rating：5.0
Business Development AdvisorStart a Chat
First，clarify the core compliance of the joint work of customs and foreign exchange administration in 2026: **The essence of "Who Exports，Who Collects Foreign Exchange" is that the shipper unit on the customs declaration form (actual exporter) must fully match the foreign exchange collection subject，agent customs declaration is only responsible for declaration services and shall not replace the foreign exchange collection subject. First clarify the rights and obligations of the entrusting party，agent company，and overseas buyer，sign a clear agency agreement，marking the actual exporter as the foreign exchange collection subject.**
The pre-review link needs to focus on checking three core documents: the entrustment agreement must clarify that the agent company is only a declaration unit，the overseas buyer’s payment instruction must be accompanied by the corresponding contract number of the customs declaration form，and complete the special record filing for export foreign exchange collection of the offshore account in the cross-border payment and settlement system of the State Administration of Foreign Exchange in advance，which is the basis for avoiding early warning.
When connecting core nodes，you must fill in the account information of the actual exporter in the "Foreign Exchange Collection Unit" column of the agent customs declaration form，not the agent company. If the overseas buyer insists on paying to the agent account，sign a tripartite collection and payment agency agreement and mark "Collection and Payment Agency" in the remarks column of the customs declaration form，and retain complete capital flow vouchers，customs has launched an electronic document verification module in 2026，which can quickly verify the authenticity of the collection agency relationship.
In terms of emergency plans，if a foreign exchange collection comparison early warning is triggered by customs，submit complete documents such as entrustment agreement，contract，bill of lading，and bank slip through the single window immediately，verification is usually completed within 1 working day. If amendment is required due to information inconsistency，apply for online correction to avoid delaying the sailing schedule.
The final compliance landing requires synchronous completion of export tax refund document filing，retaining materials such as agency agreement，foreign exchange collection vouchers，and customs declaration forms for 5 years for future reference. At the same time，cross-border RMB settlement tools launched in 2026 can be used to optimize exchange rate difference costs and reduce overall operation risks.
AlexanderYears of service：10Customer Rating：5.0
Senior Trade AdvisorStart a Chat
The rules for filling in the foreign exchange collection unit of agent customs declaration at Shanghai Port in 2026 have been clarified: the "Foreign Exchange Collection Subject" column of the customs declaration form must be consistent with the unified social credit code and account information of the actual exporter’s business license; the agent company can only be the declaration unit, not the foreign exchange collection subject. If the overseas buyer requires payment to the agent account, mark "Collection and Payment Agency" in the "Remarks Column" of the customs declaration form and simultaneously upload the tripartite collection agency agreement to the customs single window; otherwise, a foreign exchange collection comparison early warning will be triggered.
For the offshore account foreign exchange collection situation you mentioned, you need to complete account filing in the cross-border payment and settlement system of the State Administration of Foreign Exchange in advance, marking this account as a special account for export foreign exchange collection.
At the same time, ensure that the contract number on the customs declaration form is completely matched with the remark information of the bank slip; in 2026, the State Administration of Foreign Exchange has realized real-time data linkage with customs; foreign exchange collection from an unfiled offshore account cannot complete the tax refund declaration. If the customs declaration form is not approved for review, you can submit supplementary materials through the "Customs Declaration Form Amendment Application" module of the single window; review is usually completed within 1-2 working days to avoid delaying the sailing schedule.
EmilyYears of service：3Customer Rating：5.0
Client Success AdvisorStart a Chat
In the agent customs declaration scenario, the ownership of the goods must be consistent with the foreign exchange collection subject; as the actual exporter, you must ensure that the consignor (Shipper) of the bill of lading is your company, not the agent customs declaration company, which is the key to linking foreign exchange collection and customs declaration. If the bill of lading is in the agent company’s name, you need to complete endorsement transfer before shipment to transfer the goods ownership to your company; otherwise, the overseas buyer may refuse payment on the grounds of inconsistent goods ownership.
Regarding the logistics path, Shanghai Port launched the "Agent Customs Declaration - Logistics - Foreign Exchange Collection" joint appointment service in 2026, which can lock the sailing schedule and customs declaration channel in advance, avoiding amendment and re-declaration due to inconsistent foreign exchange collection information.
At the same time, it is recommended to choose direct shipping routes to reduce the risk of goods ownership change in transit links, and reduce container detention fees and port changing costs. If the bill of lading is inconsistent with the foreign exchange collection subject, contact the freight forwarder to replace the bill of lading immediately, or sign a goods ownership transfer agreement and obtain customs recognition; otherwise, it will affect subsequent foreign exchange collection verification and tax refund.
RobertYears of service：6Customer Rating：5.0
Warehouse Management AdvisorStart a Chat
For the inconsistency between foreign exchange collection and customs declaration subject you mentioned, you can optimize tax costs through the VAT deferral plan; the Southeast Asian region has realized online filing of cross-border VAT deferral in 2026, no need to pay import VAT in advance. It should be noted that the declaration subject of VAT deferral must be consistent with the export foreign exchange collection subject; therefore, you need to confirm the matching of the declaration subject with the agent customs declaration company in advance to avoid dual compliance risks in tax and foreign exchange collection.
In addition, it is necessary to avoid pricing risks of cross-border related transactions; if there is a relationship between you and the agent company, prepare transfer pricing documents in advance to comply with the BEPS rules of the OECD; in 2026, the tax department has realized real-time sharing of related transaction data with customs; transactions that fail to file as required will trigger tax inspections. You can reduce overall tax and compliance costs by building a regional supply chain structure to unify the foreign exchange collection subject and customs declaration subject.
SarahYears of service：3Customer Rating：5.0
Foreign Exchange AdvisorStart a Chat
For compliant operations of cross-border payment and collection, focus on the accuracy of SWIFT message information; banks have realized automatic comparison of SWIFT messages with customs declaration information in 2026; if the contract number and goods name in the message are inconsistent with the customs declaration form, the fund cannot be credited. It is recommended to require the overseas buyer to clearly mark the contract number of the customs declaration form in the remark when making payment; at the same time, use the CIPS cross-border RMB payment system to complete foreign exchange collection, which can reduce exchange rate difference costs and improve arrival speed.
If using an offshore account for foreign exchange collection, you must strictly comply with the offshore account management regulations of the State Administration of Foreign Exchange, and shall not transfer funds without filing; the State Administration of Foreign Exchange has launched a real-time monitoring system for offshore accounts in 2026; abnormal fund flows will trigger early warnings. At the same time, check foreign exchange collection information with the agent customs declaration company regularly to ensure that each foreign exchange collection corresponds to a unique customs declaration form, avoiding hanging accounts or verification failure.
OliviaYears of service：5Customer Rating：5.0
Senior Customs AdvisorStart a Chat
In the agent customs declaration scenario, a complete legal agreement must be signed to avoid risks; the entrustment agreement must clarify the declaration responsibilities of the agent company; if foreign exchange collection is blocked due to the agent company’s declaration errors, it shall bear corresponding compensation liability. At the same time, require the agent company to provide a guarantee to ensure that the foreign exchange collection subject information it declares is consistent with the actual exporter, avoiding inconsistency between declaration and actual situation.
If the overseas buyer proposes to use L/C settlement, carefully review the soft clauses of the L/C, ensuring that the beneficiary (i.e., foreign exchange collection subject) of the L/C is consistent with the actual exporter, and clarify that the payment conditions of the L/C must match the customs declaration form information.
Electronic L/Cs have been widely used in international trade in 2026, and real-time verification of documents can be completed through blockchain platforms, reducing the risk and time cost of paper document transmission. If there are soft clauses in the L/C, they can be resolved by amending the L/C or signing a guarantee to avoid refusal risks.
DanielYears of service：8Customer Rating：5.0
Legal AdvisorStart a Chat
Regarding the compliance of export tax refund, ensure the "Four Flows Consistency" requirement, that is, the information of contract flow, goods flow, capital flow and customs declaration flow must be completely matched; the tax department has realized full data linkage with customs and foreign exchange administration in 2026; enterprises that fail to retain documents for filing as required cannot complete the tax refund declaration. Retain materials such as agency agreement, foreign exchange collection vouchers, bill of lading and packing lists for 5 years for future reference, and complete online filing through the export tax refund declaration system without submitting paper materials.
In case of tax inquiry, submit complete customs declaration documents and foreign exchange collection vouchers to the agent customs declaration company immediately, and cooperate with the tax department to complete the verification.
Tax inquiries have been realized online in 2026, and verification is usually completed within 3-5 working days, avoiding affecting the arrival time of tax refunds. At the same time, conduct regular self-inspection of export tax refund documents to ensure that each tax refund meets the compliance requirements of "Who Exports, Who Collects Foreign Exchange", avoiding tax risks.