New Chinese Export Compliance Regulations Effective 1 October 2025
We wish to bring to your attention upcoming changes to Chinese export regulations that will impact manufacturers, suppliers, and shippers. These rules, announced by the Chinese State Taxation Administration, will be enforced from 1st October 2025.
KEY CHANGES:
Exporter Registration:
All exporters must complete registration with Chinese tax authorities before export customs clearance can occur.
End of Third-Party Declarations:
Using an unrelated company’s name or licence to declare exports will no longer be permitted.
Dual-Title Requirement:
Factories without their own export licence must still be listed on customs documents as the “production and sales entity.” Their full details (name, address, tax ID) will need to be disclosed for verification.
PATHWAYS TO COMPLIANCE
Manufacturers can comply by:
Amending their registered business scope to include “import & export.”
Registering via China’s Single Window System.
Completing registration with local tax authorities (including export rebate verification, where applicable).
IMPACT ON SUPPLY CHAINS
Ex-Works (EXW) and Free Carrier (FCA) shipments may face additional risks if shippers do not fully understand their document obligations.
Delays are possible in late September as new border control procedures are phased in. Shipments rolling from September into October could be affected.
Non-compliance risks include fines, rejected shipments, and potential legal penalties issued by the Chinese Authorities.
RECOMMENDED ACTIONS:
We strongly recommend initiating discussions with your clients to review their supply chain, ensuring their shippers /suppliers/ manufacturers are prepared for compliance requirements and can minimise any potential disruptions to shipments originating from China.
Here is a summary of two recent announcements from the Chinese authorities that affect exporters and their service providers.
Announcement No. 8 (2025) relates to VAT/Consumption-Tax Export Administration, while Announcement No. 17 (2025) covers Corporate Income Tax (CIT) reporting for agent exports. Both come into effect from 1 October 2025.
Announcement No. 8 (2025): VAT/Consumption-Tax Export Administration
• Introduces stricter requirements for VAT and consumption-tax administration on exports.
• Applies to exporters and relevant service providers involved in cross-border transactions. • Requires improved documentation and compliance with tax filing obligations.
• Penalties apply for late or inaccurate submissions.
• Expected to increase scrutiny of export transactions and impact supply chain administration.
Announcement No. 17 (2025): Agent Export CIT PrePayment Reporting
• Establishes requirements for Corporate Income Tax (CIT) reporting by agent exporters.
• Ensures that agent exports are accurately reported for tax purposes.
• Introduces obligations on intermediaries to declare transactions on behalf of clients.
• Effective 1 October 2025, with penalties for non-compliance.
• May affect contractual arrangements between exporters and service providers.
Key China Export Rule Changes:
1. End of Third-Party Exporting Shipments must be declared under the exporter’s own licence. The previously accepted practice of using a third party to lodge declarations on their behalf is now prohibited. NB. If a factory exports directly (without using an agent), this new requirement does not impact them.
2. Mandatory Tax Registration Exporters of goods subject to VAT or consumption tax must now be registered with the Chinese tax authorities prior to customs clearance.
3. Factory Details on Export Paperwork Where a factory does not hold its own export licence, all export paperwork must still include:
• The licensed customs broker, and
• The manufacturer’s legal name, registered address, and tax ID.
4. Alignment with Domestic Tax Rules China has brought export taxation in line with domestic tax rules. This means exporters may face VAT, consumption tax, and corporate income tax obligations on goods leaving the country.
Summary
Please liaise closely with your Chinese suppliers and agents to ensure proper arrangements are made ahead of the 1 October 2025 cutover to avoid potential delays, disruptions and financial penalties.
The DDWL Team
Story courtesy of IFCBAA