Which actions will be deemedAgency export,Non-compliant?

Pursuant to the Regulations on the Implementation of Customs Administrative Penalties newly enacted in 2025, the following three categories of conduct will constitute violations in export agency:

• document fraud
  • Forging or altering customs declarations, certificates of origin, and other clearance documents
  • Falsely declaring product codes, specifications or transaction prices
• Violation of trade methods
  • evading through the "buy-out export" methodExport tax refundRegulation
  • False declaration of special regulatory methods such as cross-border e-commerce
• Credential Misuse
  • Unauthorized use of another company's export rights
  • Fraudulently using the qualifications of an AEO-certified enterprise for customs clearance

What are the new changes to the 2025 administrative penalty standards?

General Administration of Customs of the People’s Republic of China Announcement No. 17 of 2025 stipulates:

• Upgrade of the Fine Calculation Benchmark: Based on 30% of the total value of the goods involved, a fine of up to three times that amount may be imposed.
• Strengthening the Effectiveness of Electronic Evidence: Electronic data modification records of the customs declaration may serve as direct grounds for penalty.
• Joint Punishment Mechanism: Violating enterprises will be simultaneously referred to the State Administration of Foreign Exchange and the tax authorities for joint supervision.

What circumstances might constitute a criminal offense?

Provisions of the 2025 Judicial Interpretation by the Supreme People's Court:

• Crime of Smuggling Ordinary Goods: Evading payable duties exceeding RMB 500,000 constitutes the threshold for criminal case filing.
• defraudExport tax refundsin: Falsely declaring export amounts exceeding RMB 1 million will be referred to judicial authorities
• Document-related crimes: Three or more instances of forging or trafficking in permits issued by customs

How can a company recover after its credit is damaged?

2025 Customs Credit Management Measures – Restoration Pathway:

• Generally Dishonest Enterprise: Credit repair may be applied for after a 6-month observation period
• Seriously Dishonest Enterprise: Three remediation conditions must be met:
  • Full payment of the fine for 12 consecutive months
  • Complete the certification of the compliance system construction
  • Pass the customs-specific compliance review

How to avoid compliance risks in export agency arrangements?

Recommendation based on 20 years of agency service experience:

• Criteria for Selecting an Agency
  • Verify its customs AEO certification qualifications
  • A certificate of no violations for the past three years is required.
• Key Control Points in the Transaction Process
  • Establish a three-tier review system for export documents
  • Retain complete logistics tracking proof materials
• Risk early warning mechanism
  • Monthly verification of the credit disclosure on the Customs "Single Window" platform
  • Set the early-warning threshold for abnormal fluctuations in export unit prices

Typical Case Alerts (Latest Circular of 2025)

Case 1:A certain freight forwarder was fined 2.1 times the value of the goods (a total of RMB 3.87 million) for tampering with the HS codes on 15 customs declarations, and its legal representative was placed on the industry blacklist.

Case 2:Export enterprises inflated their input tax credits through “invoice-and-goods matching” fraud, involving a total tax refund of RMB 2.1 million; three responsible individuals were sentenced to 3–5 years in prison.