Does agency export count as entrepot trade? Analysis of compliance key points that must be known in foreign trade in 2025

I. Agency Exports andEntrepot TradeAre they the same concept?

In international trade practice,There is an essential difference between agency export and entrepot trade.According to the latest interpretation clauses of the WTO Trade Facilitation Agreement in 2025:

• Foreign Trade Agency AgreementDomestic enterprises entrust qualified companies to handle export procedures such as customs declaration and tax refund, and the goods are directly transported from the producing country to the destination country.import and exportThe goods actually transit through a third country (region), and there is a trade behavior of transfer of property rights and logistics transit.
• Entrepot TradeAccording to the Guidelines for Determination of Trade Modes issued by the General Administration of Customs of China in 2025, special attention should be paid to the following scenarios:

II. What Circumstances May Trigger the Identification of Entrepot Trade?

Abnormal flow of goods:

• The bill of lading shows that the transit port stay exceeds 72 hours.
  • The consignee recorded in the transport document is inconsistent with the trade contract.
  • Abnormal flow of funds:
• The receipt and payment of foreign exchange involve more than three countries/regions.
  • There is a settlement currency that does not match the logistics route.
  • The new version of the Administrative Measures in 2025 clearly stipulates three high - risk situations:

III. Can Improper Operation of Agency Exports Turn into Entrepot Trade?

The agent changes the transportation terms without authorization and adds unauthorized transshipment terms.Export DrawbackThe manufacturer information shown on the export documents (such as ) does not match the agents filing information.

• There are multiple sets of contradictory trade documents for the same batch of goods.
• A case of an electromechanical export enterprise in 2023 shows that due to the agents unauthorized change of the port of discharge, the enterprise was recovered the tax refunded and fined 820,000 yuan.It is recommended to verify through the following methods:Based on the latest regulatory requirements, the following measures are recommended:
• Triple verification of document management

The value error between the commercial invoice and the customs declaration should not exceed ±2%.

IV. How to Ensure Compliance of Agency Exports in 2025?

The transport document must mark the DIRECT SHIPMENT clause.

• The certificate of origin needs to be electronically verified by the China Council for the Promotion of International Trade.:
  • Standards for selecting agents
  • Check the AEO certification records of the customs in the past three years.
  • Confirm that its ERP system is directly connected to the single window.
• Require the provision of a compliance audit report for the most recent 12 months.:
  • According to the Cross - border Trade Dispute Disposal Procedures implemented in 2025, it is recommended to handle it in three steps:
  • Step 1: Submit evidence chains such as the original contract, logistics track map, and bank statement within 72 hours.
  • Step 2: Apply to a third - party institution (such as SGS) to issue a trade process verification report.

V. How to Respond When Encountering a Suspected Entrepot Identification?

Step 3: Initiate a rapid mediation procedure through the International Trade Arbitration Commission.

• A case of a textile exporter in 2024 shows that the completely preserved email communication records and blockchain logistics evidence enabled it to successfully overturn the misjudged entrepot trade determination.
• How do agency export enterprises declare? These 10 key questions must be mastered!
• Is agency export considered entrepot trade? Analysis of compliance key points that must be known in foreign trade in 2025_Shanghai Zhongshen International Trade Import and Export Agency Service

Based on 20 years of foreign trade agency experience, this article systematically analyzes the key processes, compliance key points, and risk prevention strategies for the import of automotive lamps. The article details the characteristics of the global automotive lamp market, the entire import process, high - risk links, and risk control strategies, and looks ahead to the trends of industry intelligence, green customs clearance, and digital services, helping enterprises to efficiently complete cross - border procurement.