Can an Import & Export Agency Conduct Independent Import Business? 2026 Latest Compliance Guide

1.Clarify First: The Authority Boundary of Self-operated Import for Import and Export Agencies

In 2026,global trade compliance regulation continues to tighten,the control rate at Shanghai ports has increased by 12% compared with 2025,and many clients engaged in foreign trade have consulted us: we are an import and export agency,can we take import orders on our own?The core of this question is not whether it is allowed in general,but whether it can be conducted in a compliant manner.In accordance with General Administration of Customs Announcement No.12 of 2026,the core qualification of import and export agencies is to provide intermediary services including customs declaration,foreign exchange receipt and payment,and tax refund for third parties,which does not require additional self-operated import and export right filing.While for self-operated import,enterprises must hold valid filing of import and export operation right,and use their own corporate public accounts for foreign exchange settlement.

The red line here is very clear: if an agency has not completed the self-operated import and export right filing,but signs import contracts in its own name,this constitutes business beyond the approved scope.In 2026,the document withholding rate for such violations at Shanghai Waigaoqiao Port reaches 92%.Once identified,the agency will not only be required to return the documents for rectification,but also be recorded in the customs credit file,which will affect subsequent customs declaration business.

2.Practical Operation Process and Core Nodes for Self-operated Import in 2026

If your agency has completed the filing of self-operated import and export operation right and intends to carry out self-operated import business,you need to follow the four core steps below:

• Step 1: Complete AEO certification filing.In 2026,the customs clearance efficiency for AEO Senior Certified Enterprises at Shanghai ports is increased by 30%,but the certification requires meeting requirements such as no violation records for 12 consecutive months and financial compliance,with a cycle of around 45 working days.
• Step 2: Accurately classify HS codes.Over 1200 HS codes have been updated globally in 2026,with the largest adjustments for machinery,chemical and electronic products.For example,the HS code for vertical machining centers is adjusted from 84571010 to 84571020,and incorrect classification will lead to a price review difference of up to 15%.
• Step 3: Prepare full sets of compliant documents.In addition to conventional commercial invoices,packing lists and bills of lading,if you import chemical products,MSDS that meets the 2026 GHS standard must be provided; if you import goods from RCEP member states,you need to apply for a certificate of origin in advance,so as to enjoy 5%-10% tariff reduction.
• Step 4: Declaration and inspection response.The average inspection rate at Shanghai ports in 2026 is 8.7%.If the declared elements do not match the actual goods,you will be required to return documents for rectification,and demurrage will be charged at 0.05% of the cargo value per day.

3.Practical Case: Lessons Learned from Self-operated Import of a Chemical Agency in Shanghai

In November 2025,a Shanghai chemical import and export agency that had only provided agency services before and had just completed the self-operated import and export right filing intended to conduct self-operated import of a batch of polyurethane raw materials from Germany.When preparing for declaration,they ignored the new "chemical component disclosure" requirement released by customs in 2026,and failed to specify the specific component ratio of the raw materials in the declared elements,which triggered targeted inspection by Beilun Port of Ningbo.Without preparing component test reports in advance,they were required to return documents for rectification,the goods were detained for 12 days,resulting in demurrage of 180,000 RMB,delayed delivery for domestic clients,and 5% of liquidated damages paid.Later,they contacted us,and we assisted in rearranging the declared elements and supplemented third-party test reports,so that the goods were cleared smoothly.This case shows that the compliance requirements for self-operated import are far higher than those for agency services.

4.Core Risks and Prevention & Control Suggestions for Self-operated Import

• Exchange Loss Risk: In 2026,the RMB exchange rate fluctuation band is expanded to ±7%.Enterprises conducting self-operated import need to lock the exchange rate on their own,otherwise exchange loss of 5%-8% may occur.We suggest entrust professional institutions to handle forward foreign exchange settlement and sale,to control the exchange loss within 1%.
• Compliance Risk: Incorrect HS code classification,inconsistent declared elements,incomplete documents will lead to a fine of 1%-3% of the cargo value imposed by customs,and will also affect the enterprise’s credit rating.We suggest inviting a professional team to review the declaration materials in advance to avoid violations.
• Logistics Risk: Public holidays at destination ports (such as the Christmas season in Europe and America,Ramadan in the Middle East) will increase the customs clearance delay rate by 40%.It is necessary to make logistics plans in advance and reserve a buffer period of at least 10 days.
• Anti-dumping Risk: If you import products restricted by anti-dumping measures such as steel and photovoltaic products,you need to calculate the anti-dumping duty in advance,otherwise extra tax expenditure will be incurred.

5.When Is It Suitable for Import and Export Agencies to Conduct Self-operated Import?

Only when your agency meets the following three conditions,it is suitable to carry out self-operated import business:

• Own stable overseas supplier resources and be familiar with the trade policies of target countries;
• Have a mature domestic client group,and can ensure the sales channels of imported goods;
• Have sufficient risk control capabilities to bear risks such as inspection,demurrage and exchange loss.

If your agency only intends to conduct self-operated import on a trial basis,or does not have sufficient risk control capabilities,we suggest accumulating experience through agency services first,and expanding self-operated business after the qualifications and processes are fully mature.After all,foreign trade supervision will be increasingly strict in 2026,and compliance is always the top priority.

In general,whether an import and export agency can conduct import business on its own depends on its qualifications and compliance capabilities.If your agency has completed the self-operated import and export right filing and has sufficient risk control capabilities,you can try to carry out self-operated import business; if not,it is recommended to focus on agency services first,and expand self-operated business when conditions are mature.As a local foreign trade agency based in Shanghai,we have frontline practical experience,and can provide you with full-link compliance services to help you avoid risks and improve customs clearance efficiency.