Can Foreign Trade Companies Legally Conduct Import Agency Business? 2026 Latest Policy Interpretation

Can Foreign Trade Companies Legally Conduct Import Agency?Core Qualifications and Practical Guide

In the 2026 foreign trade market,many foreign trade companies with import and export rights are consulting the same question: are we allowed to conduct import agency business?Last week,Ms.Qian came to us with an agency contract for purchasing German machine tools.Her company has completed the customs registration for consignees and consignors,but is not sure if it has the qualifications for import agency,nor does it know how to avoid compliance risks.As an agency team with years of in-depth practice at Shanghai Port,we break down this question from a practical perspective,and help you sort out all relevant details.

Core Qualifications and Access Requirements for Foreign Trade Companies Conducting Import Agency

First,the clear answer is: foreign trade companies can legally carry out import agency business in 2026,as long as they meet the basic qualification requirements and special permit requirements.According to the newly revised *Measures for the Administration of Registration of Consignees and Consignors of Import and Export Goods* released by the General Administration of Customs of China,the binding restriction between business scope and import agency business has been cancelled since 2025.Any entity that obtains the Customs Registration Certificate for Import and Export Goods Consignees and Consignors can take import agency orders.However,for specific product categories,additional special permits are still required:

• Mechanical and electrical equipment: An Automatic Import License is required.For used mechanical and electrical products,pre-shipment inspection and quarantine for imported used mechanical and electrical products shall be completed in advance.
• Chemical products / dangerous goods: MSDS report,dangerous goods classification appraisal certificate are required,and import filing of dangerous goods at the local customs authority shall be completed.
• Food,cosmetics,medical devices: Corresponding import filing certificates issued by the National Health Commission are required,and medical devices also need to obtain the NMPA registration certificate.

It should be reminded here that some foreign trade companies mistakenly believe that adding the words "import agency" to their business scope is required.However,all customs authorities across China have fully cancelled this pre-condition in 2026,and completing the registration is all that is needed.If the products under agency involve special permits,it is recommended to confirm the permit applicant with the client in advance.Usually,the agency assists the client to complete the relevant formalities.

Core Operation Process of Import Agency in 2026 (Taking Shanghai Port as an Example)

As China’s largest import port,Shanghai has seen its customs clearance efficiency increase by 32% in 2026 compared with 2023,but three core nodes still need strict control:

1.Pre-examination of documents and accurate classification of HS codes

This is the most error-prone link.In 2026,the customs control and inspection model has been fully upgraded,which compares the consistency between declaration elements and physical goods based on big data.Any deviation will most likely trigger customs inspection.In Ms.Qian’s procurement order for German machine tools,the initially declared HS code was 84569090,with a corresponding tariff rate of 8%.However,our supervisor Ke,after checking the technical parameters of the equipment,found that the 5-axis simultaneous machining accuracy of the machine tool conforms to the tariff description of HS code 84563010,with a corresponding tariff rate of only 5%,which also avoided subsequent price verification disputes.

In terms of practical details,we will require clients to provide full sets of materials such as equipment nameplates,technical manuals,purchase contracts and commercial invoices,classify the goods in accordance with the 2026 version of *Import and Export Tariff*,and meanwhile apply for customs advance ruling on classification to obtain the official classification confirmation letter,so as to completely eliminate the risk of subsequent document amendment.

2.Special permit application and compliance preparation

For special permits of different product categories,we will start the application process 15-20 working days in advance.Taking mechanical and electrical products as an example,the Automatic Import License has been processed through nationwide online system,and there is no need to submit paper materials to local customs authorities,but the qualifications of the import entity and the authenticity of the purchase contract need to be verified.If the imported goods come from RCEP member economies,the certificate of origin shall be reviewed in advance to ensure compliance with accumulation rules and enjoy the lowest tariff rate.In 2026,the number of RCEP member economies has increased to 16,including Japan,South Korea,Australia and others.The compliant use of certificate of origin can directly reduce import costs by 10%-15%.

In addition,for goods from trade partners such as the European Union and the United States,the latest policies on anti-dumping duties and anti-subsidy duties shall be checked in advance.In 2026,the European Union still imposes anti-dumping duties on some Chinese steel products,and in turn,China also maintains anti-dumping duties on some EU chemical products.Cost calculation in advance can avoid budget deviation of clients.

3.Port customs clearance and inspection response

The "Advance Declaration,Two-step Declaration" mode implemented at Shanghai Port in 2026 helps foreign trade companies shorten the customs clearance time to 3-5 days,which greatly reduces the occurrence of demurrage.Our team completes the review and declaration of all documents 7 days before the arrival of goods.In case of customs control inspection,we will assign special personnel to accompany customs officers to check the consistency between physical goods and declaration elements,and provide supporting documents for transaction price such as bank payment slips,ocean bills of lading and transport insurance policies to ensure smooth customs inspection.

In Ms.Qian’s order,the goods departed from the Port of Hamburg and arrived at Shanghai Yangshan Port after 21 days of sea transportation.We completed the declaration 3 days in advance,and the goods completed customs clearance only 2 days after arrival without any demurrage,which was highly recognized by the client.

3 Core Risks of Foreign Trade Import Agency and Avoidance Solutions

In import agency business,the most common risks are concentrated in three aspects.We provide avoidance solutions based on the 2026 market situation:

• Exchange loss risk: In 2026,the fluctuation range of RMB exchange rate expands by 25% compared with 2023.Many foreign trade companies do not stipulate the sharing method of exchange rate fluctuation in agency contracts,resulting in extra exchange loss borne by clients.For example,Ms.Qian’s order is settled in EUR.Within 30 days from contract signing to foreign exchange payment,the EUR appreciated by 3.2%,leading to an extra cost of 128,000 RMB for the client.Our suggestion is to specify the sharing ratio of exchange rate fluctuation in the agency contract,or use forward foreign exchange settlement and sale tools to lock the exchange rate,so as to keep exchange loss within a controllable range.
• Demurrage trap: In 2026,the storage fee and container detention fee at Shanghai Yangshan Port are charged in a stepped pattern.The storage fee increases by 50% per day for storage over 7 days,and the fee doubles for storage over 14 days.Many foreign trade companies fail to prepare documents in time,so that the goods cannot be declared promptly after arrival,resulting in high demurrage.Our suggestion is to start document review 7 days in advance,and meanwhile agree on the sharing method of demurrage with the freight forwarder.If the demurrage is caused by the agency,the agency shall bear all relevant costs.
• Compliance red line risk: In 2026,customs authorities have strengthened penalties for false declaration,with a maximum fine of 5 times the value of the goods,and the violating enterprises will be included in the joint disciplinary list for untrustworthy entities.In a false declaration case cracked down by Shanghai Customs in 2025,a foreign trade company under-reported the transaction price of equipment to reduce tariffs,and finally not only supplemented the payable taxes and late fees,but also had its import and export operating right suspended for 6 months.Our suggestion is to declare strictly in accordance with the information of physical goods and contracts,and never adjust the transaction price without authorization.If there is any doubt about the declared price,enterprises can apply for price negotiation with customs authorities.

Comparison Between Self-conducted Import and Entrusted Import Agency

Latest Policy Changes for Foreign Trade Import Agency in 2026

The foreign trade policy changes in 2026 are mainly concentrated in four aspects,which directly affect the operation of import agency business:

• The business scope requirement for registration of consignees and consignors of import and export goods is cancelled.Completing the relevant registration is the only requirement to carry out import agency business,which greatly lowers the market access threshold for enterprises.
• The Automatic Import License is processed through nationwide online system.Enterprises can apply directly via the "Single Window" without submitting paper materials to local customs authorities,and the processing time is shortened from 3 days to 1 day.
• Customs authorities have implemented the "Advance Ruling" system.Enterprises can apply for advance rulings on HS code classification,certificate of origin,permit qualifications and other matters in advance.Official confirmation can completely avoid subsequent disputes.
• Imported goods from RCEP member economies can enjoy lower tariff rates.In 2026,the number of RCEP member economies has increased to 16,including Vietnam,Malaysia,Japan and others.Compliant use of certificate of origin can directly reduce import costs by 10%-15%.

Back to Ms.Qian’s case,we finally helped her complete the full import agency process,including HS code classification,Automatic Import License application,customs clearance declaration and inspection response.The goods were smoothly delivered to the client.The client not only saved nearly 200,000 RMB in tariff costs,but also avoided all compliance risks.

In general,foreign trade companies can legally carry out import agency business,but they need to hold basic registration qualifications,and strictly control links such as documents,compliance and risks.If you do not have sufficient experience in import agency,entrusting a professional agency can help you save time,reduce costs and avoid risks.In particular,the agency team based at Shanghai Port has the ability to link up with ports across the country,and can provide clients with one-stop services including off-site declaration and nationwide customs clearance.