Compliance Red Lines and Practical Procedures Entrusting Parties Must Know for Entrusted Import Agency

Compliance Red Lines and Practical Procedures Entrusting Parties Must Know for Entrusted Import Agency

As an entrusting party for entrusted import agency,the core demand is to safely and compliantly introduce high-quality overseas goods into China while avoiding additional costs caused by information asymmetry.The new Guidelines on Customs Pricing Verification of Imported Goods issued by the General Administration of Customs in 2026 clearly stipulates that a "double random + key inspection" mode will be implemented for high-value industrial products,luxury goods,and sensitive categories.This requires entrusting parties and agents to form an information closed-loop.

I once worked with a Mr.Wei whose company entrusted an agent to import precision instruments from Germany.Due to the failure to fill in the "calibration certificate number" in the declaration elements,the commodity inspection bureau directly judged it as "document discrepancy",resulting in the goods being detained at Yangshan Port for 14 days.This is a typical case where the entrusting party provided incomplete information and the agent failed to verify it in a timely manner.

I.Core Boundaries of Rights and Responsibilities for Entrusted Import Agency

• Entrusting Party’s Information Responsibility: Must provide the agent with genuine product manuals,certificates of origin,and international transport documents (bill of lading/waybill).Especially for goods involving animal and plant quarantine or radioactive testing,it is necessary to confirm in advance whether they meet the requirements of Article 12 of the List of Inbound Articles of the People’s Republic of China.
• Agent’s Compliance Guarantee: The agent must complete the preliminary HS code determination within 48 hours after receiving the entrustment.For goods suspected of being involved in anti-dumping (such as stainless steel tableware made in the US) or requiring 3C certification,the agent must simultaneously verify the 2026 Anti-Dumping Duty Adjustment List.

II.Customs Pricing Verification: Full-chain Control from Contract to Pricing Verification

Customs pricing verification is not simply "price checking",but a comprehensive judgment based on the Measures for Customs Determination of Dutiable Value of Imported and Exported Goods (Decree No.252).Entrusting parties should note: if the imported goods are used equipment (under EXW terms),they must provide proof of production year and depreciation calculation sheet; otherwise,the customs may assess the value based on "new similar equipment".

I once handled a case where an entrusting party imported used textile machines from Switzerland.Since only the purchase invoice was provided without a depreciation sheet,the customs finally levied taxes based on the 2026 Guiding Prices for Imported Used Equipment (referring to data released by Shanghai Customs),resulting in an additional expenditure of RMB 123,000.After the agent supplemented the certificate of origin,factory serial number,and usage records at the time of import,the customs re-calculated and adjusted the tax base.

III.Commodity Inspection Pre-review and Animal & Plant Quarantine: Avoiding "One-vote Rejection"

Article 19 of the newly revised Regulations for the Implementation of the Import and Export Commodity Inspection Law in 2026 stipulates that for cosmetics and food additives involving human health,the "electronic supervision form" must be filed 72 hours before the goods arrive.Entrusting parties should note: if the agent fails to complete the inspection within the validity period of the Entry Goods Clearance Form,the goods will not be allowed to be warehoused.

Typical case: An entrusting party imported dried durian from Thailand.The entrusting party failed to verify the Import Animal and Plant Quarantine License in advance,and the agent found that the quarantine certificate was missing after the goods arrived at the port,resulting in the goods being detained at the terminal with demurrage fees of RMB 21,000 per day.After emergency coordination,the agent submitted supplementary materials through the "pre-declaration channel" at Shanghai Port,and finally completed the inspection and release on the 5th day.

IV.Import License Processing: Newly Added "Special Supervision Categories" in 2026

According to the 2026 Import License Management Catalog,in addition to traditional mechanical and electrical products and ozone-depleting substances,the category of "Import of AI Training Data" has been newly added.Entrusting parties should note: if the import involves AI training data,the purpose of the data must be clearly stated in the Technology Import Contract Registration Certificate; otherwise,the customs may classify it as "unlicensed data export" and impose administrative penalties.

Risk Warning: Entrusting parties must not choose unlicensed agents to "save costs".Zhongshitong’s Q1 2026 data shows that inspection delays caused by unlicensed agents increase by an average of 3.2 days,and the fines incurred account for 15%-20% of the total cost.

V.Pitfall Avoidance Guide for Import Agency Entrusting Parties in 2026

• Double-blind Verification Mechanism: The agent and entrusting party must clarify the "Declaration Element Verification Form" at the time of signing the contract.Both parties shall sign and confirm it before submitting it to the customs to avoid declaration errors.
• Anti-dumping Duty Screening: For bulk commodities such as steel and aluminum with an import volume exceeding 500 tons,the agent must verify the Anti-Dumping Duty Early Warning Report in advance,and require the entrusting party to supplement the deposit if necessary.
• Completeness of Document Chain: Ensure that the bill of lading,invoice,packing list,and certificate of origin are consistent.The certificate of origin must be verified through the China International Trade Single Window.

Final Reminder: The core of entrusted import agency is "equal rights and responsibilities".Entrusting parties must take the initiative to provide genuine information,and agents must professionally control the process.Zhongshitong always recommends that for imports of important categories (such as medical devices and hazardous chemicals),a Compliance Responsibility Agreement must be signed to clarify the boundaries of responsibilities between both parties and avoid compliance risks caused by information gaps.