How exactly should agency export invoices be issued? These 10 key questions must be clarified!

I. Who must issue agency export invoices?

According to the latest 2025 Customs Export Goods Declaration Management Measures, agency export invoices should be issued byimporters holding Customs AEO certificationExport RepresentationcompanyThe actual exporting enterprise should note:

• The agent must possess customs declaration qualification
• The invoice needs to bear the agent companys bilingual seal (Chinese-English)
• Must include the remark Agency Export and the clients Unified Social Credit Code

II. What essential materials are required for issuing agency export invoices?

Our experience with 300+ cases shows the complete material checklist should include:

• Basic documents
  • Original agency agreement (must specify settlement currency)
  • Copy of clients business license
  • Original Proforma Invoice (PI)
• Trade documents
  • Copy of Bill of Lading (must show FOB/CIF price composition)
  • It is recommended to verify through the following methods:Clear scanned copy
  • Customs declaration pre-entry form

III. What happens if invoice amount doesnt match customs declaration amount?

In 2025 Customs audit priorities, such issues cause38% ofExport DrawbackdisputesSpecial attention must be paid to:

• FOB price must exactly match the bill of lading records
• CIF price must specify the freight/insurance split ratio
• Exchange rate shall be based on the median price published by China Foreign Exchange Trade System on the invoice date

What are common invoice issuance errors?

According to our 5-year data statistics, high-frequency errors include:

• Case 1: A company wrote the first 6 digits of HS code as domestic tax number, resulting in $200,000 goods detained at port
• Case 2: Failure to specify trade terms (e.g. EXW/FCA), causing freight disputes between buyers and sellers
• Case 3: Using obsolete INCOTERMS 2020 version clauses

What are the legal requirements for invoice remarks column?

The 2025 revised Provisional VAT Regulations specifically stipulate:

• Must mark Agency Export wording
• Indicate the taxpayer identification number of the consignor
• Cross-border services require remarks on service occurrence location
• Software exports must indicate copyright registration number

How to ensure cross-border recognition of electronic invoices?

Verified effective solutions include:

• Using OECD-certified electronic signature systems
• Simultaneous transmission to importing country customs through Single Window
• Attaching PDF format UN/EDIFACT messages
• Quarterly blockchain notarization

How to modify invoices after issuance?

According to General Administration of Customs Announcement No. 58 of 2025, the modification process is:

• Under non-customs clearance status: Agency companies can directly modify in Single Window
• Under customs clearance status: Need to submit Application Form for Amendment/Cancellation of Export Goods Declaration to declaration customs
• Modification applications exceeding 90 days require third-party audit reports

What is the relationship between agency invoices and export tax rebates?

Key data correspondence relationships:

• Invoice amount must be ≥ the amount corresponding to transaction method in customs declaration
• First 8 digits of HS code must match tax refund commodity code table
• A complete export agency agreement should be attached with:The water bill number must match the information in the invoice remarks column

How to verify the authenticity of agency invoices?

Recommended three official verification channels:

• China Electronic Port Law Enforcement System (requires IC card login)
• State Taxation Administration National VAT Invoice Verification Platform
• General Administration of Customs International Trade Single Window Public Service

What risk points should be noted when selecting agency services?

Based on the dispute cases we have handled, key verification points include:

• Whether the agency company has cross-border capital pool qualifications
• Whether the historical declaration error rate is higher than the industry average (2024 industry average is 1.2%)
• Whether using a certified trade process management system
• Whether able to provide RCEP rules of origin accumulation application solutions