Import-Export Setup in China: Registrations and Practical Checklist

TL;DR

• China does not issue one universal "import-export licence" that completes the whole setup. A trading company normally coordinates corporate scope, customs filing, Single Window access, bank and foreign-exchange setup, tax treatment and product-specific controls.
• The old general foreign-trade-operator recordal was removed from the Foreign Trade Law in December 2022. That change did not remove customs, foreign-exchange, tax or controlled-product requirements.
• Start with the product, HS classification, importer or exporter of record, Incoterms, payment path and invoice flow. Registrations should follow the real transaction model.

If a new China company is expected to trade from launch, talk to ChinaBizPro before the business scope, bank package and first purchase contract are finalized. It is easier to align the setup before goods are booked.

There is no single import-export registration

"Can this company import and export?" is not answered by one certificate. A company may be properly incorporated but still unable to complete its first shipment because customs filing, electronic access, product approval, foreign-currency collection or export-tax documentation is missing.

The practical setup usually covers six layers:

1. a China legal entity with a suitable operating model and business scope;
2. filing as a customs declaration entity, normally an import-export consignee or consignor;
3. China International Trade Single Window and electronic customs access;
4. bank accounts and trade foreign-exchange directory registration;
5. tax and export VAT refund or exemption setup; and
6. licences, registrations, inspection or certification for the particular goods.

The WFOE registration guide covers the entity-establishment layer. The steps below begin where the company is expected to become the trading principal.

What changed when the foreign-trade-operator recordal was removed?

On 30 December 2022, the National People's Congress Standing Committee removed Article 9 of the Foreign Trade Law, which had required general foreign-trade operators to complete a recordal with the commerce authority. Commerce departments stopped processing that general recordal.

Some older checklists still ask for a "Foreign Trade Operator Record Registration Form." It should not be presented as a current universal step. However, removal of that form did not cancel:

• customs declaration entity filing;
• import or export licences, quotas or state-trading qualifications where applicable;
• technology-import or export procedures;
• foreign-exchange and bank checks;
• tax and export refund rules; or
• product safety, inspection, labelling and certification obligations.

Use the current process for the actual goods and city instead of copying a pre-2023 checklist.

Step 1: Define the transaction before filing

Prepare one sample import and one sample export flow. For each, identify:

• exact product and intended use;
• proposed HS code and customs description;
• country of origin and destination;
• seller, buyer and importer or exporter of record;
• Incoterm and freight responsibility;
• purchase and resale prices;
• currency, payer, payee and bank account;
• domestic VAT invoice flow;
• product licence or certification;
• warehouse or bonded-zone involvement; and
• proposed customs broker and logistics provider.

An importer of record takes responsibility for the declaration and regulatory obligations; appointing a customs broker does not transfer all liability away from the company.

Step 2: Align the company and business scope

The company's registered activities should support its real trading model. Wholesale, retail, commission agency, e-commerce, import-export and technical services can have different tax, licensing and operating implications.

Do not insert broad wording without checking the first goods. Certain products or services remain subject to foreign-investment access rules, pre-registration approval or post-registration permits. The guide to drafting a China business scope explains how to connect intended activities with registrable language.

Also confirm that the registered capital, address, personnel and accounting capacity are credible for the expected volume. Banks and customs may compare the business profile with actual transactions.

Step 3: Complete customs declaration entity filing

Under the Customs Provisions on the Filing of Customs Declaration Entities, import-export consignees and consignors and customs brokers are customs declaration entities. A company that will act as importer or exporter of record generally files its enterprise information with Customs.

Prepare current corporate and contact data, including the unified social credit code, legal representative, customs contact and other required information. After filing, maintain the data and report relevant changes or deregistration through the prescribed channel.

The filing enables the entity to handle customs declaration business within China's customs territory, but it does not approve every product or declaration.

Step 4: Configure Single Window and electronic access

The China International Trade Single Window is the main online environment used for customs and related cross-border-trade functions. The company should:

• create or activate the enterprise account;
• bind the correct users and operator roles;
• arrange the supported electronic authentication or card tools;
• give the customs broker only the necessary authorization;
• test declaration, query and document functions; and
• retain control of administrator credentials when staff or agents change.

Single Window access is an operating tool, not a substitute for a licence or filing. The company remains responsible for the data submitted in its name.

Step 5: Set up bank and trade foreign exchange

A company handling foreign-currency receipts or payments needs an account and KYC profile that support its trade. Give the bank the transaction model, countries, currencies, expected values, ownership chart and sample contracts.

Since 1 June 2024, an enterprise that will conduct foreign-exchange receipts or payments for trade in goods generally completes registration in the Trade Foreign Exchange Receipts and Payments Enterprise Directory directly with a domestic bank before its first transaction. SAFE branches no longer handle the routine directory entry. A limited exemption applies to qualifying small cross-border e-commerce enterprises using transaction electronic information, so it should not be generalized to ordinary traders.

The corporate bank-account guide explains the broader KYC preparation. Even after setup, the bank can request contracts, invoices, customs data, logistics documents and explanations for individual payments.

Step 6: Configure tax and export treatment

Import VAT and customs duty, domestic output VAT, export exemption or refund and corporate income tax need one reconciled document chain.

Before the first export, confirm:

• taxpayer status and fapiao capability;
• whether the goods and transaction qualify for export VAT refund, exemption or taxation;
• applicable refund rate and commodity code;
• export tax refund or exemption filing and system access;
• supplier special VAT invoices and input-credit treatment;
• foreign-currency receipt and customs-declaration matching;
• accounting ledgers for purchases, inventory, exports and refunds; and
• document retention.

An export does not automatically produce a cash refund. Eligibility, rates, invoices, declaration data and filing quality all matter. The China VAT and fapiao guide provides the tax foundation.

Step 7: Check product-specific requirements

Create a product compliance matrix before ordering. Depending on the goods, the project may involve:

• import or export licences or quota administration;
• food, agricultural or animal and plant quarantine requirements;
• medical-device, pharmaceutical or cosmetics registration;
• China Compulsory Certification or other conformity assessment;
• hazardous chemicals and transport controls;
• dual-use or export-control rules;
• endangered-species documentation;
• Chinese labelling and consumer standards;
• energy, radio or cybersecurity approvals; or
• destination-country restrictions for exports.

This list is illustrative, not exhaustive. Requirements can turn on HS code, product specification, intended use, origin, destination and trading method.

Documents to have ready

A practical file usually includes:

• business license and articles;
• legal representative and authorized-user records;
• company chops and electronic-authentication controls;
• customs filing confirmation and Single Window account details;
• bank KYC and trade foreign-exchange directory result;
• product descriptions, specifications, photos and proposed HS codes;
• supplier and customer contracts;
• Incoterms, packing, freight and insurance arrangements;
• product licences, certificates and labels;
• VAT invoices, customs declarations and logistics records;
• tax refund or exemption records; and
• a responsibility matrix for the company, broker, freight forwarder and warehouse.

Common mistakes

1. Following an old checklist that still requires the general foreign-trade-operator recordal.
2. Registering first and identifying the product requirements only after shipment.
3. Letting a customs broker choose an HS code without internal technical support.
4. Assuming the broker becomes legally responsible for every declaration issue.
5. Using inconsistent product descriptions across contracts, fapiao, customs and bank documents.
6. Receiving or paying foreign currency before the bank profile and directory entry are ready.
7. Treating export VAT refund as guaranteed margin.
8. Giving an employee or agent sole control of Single Window and electronic credentials.
9. Forgetting to update customs, bank and tax information after a company change.

Timing and cost drivers

There is no useful single national setup time. A standard unrestricted product with complete corporate records is different from food, medical devices, chemicals, controlled technology or goods needing testing.

Budget for:

• company or scope changes;
• customs and electronic access;
• bank and foreign-exchange onboarding;
• tax system and accounting setup;
• product testing, certification or registration;
• translations and technical files;
• customs broker, freight forwarder and warehouse services; and
• internal inventory, invoice and compliance controls.

Do not schedule the first commercial shipment until each owner confirms readiness in writing.

Frequently asked questions

Does every WFOE automatically have import-export rights?

No. Incorporation alone does not complete the operational layers. The company's activities, customs filing, electronic access, banking, tax and product rules must support the transaction.

Is the foreign-trade-operator recordal still required?

The former general commerce-authority recordal was removed from the Foreign Trade Law in December 2022. Other registrations and controlled-trade requirements remain.

Can a customs broker handle everything?

A broker can submit declarations and provide operational support, but the importer or exporter must understand and support the classification, value, origin, product compliance and transaction data submitted in its name.

Can a company outsource importing to a distributor?

Yes, if the contract clearly allocates importer-of-record, title, tax, product, warranty, data and payment responsibilities. That is a different operating model, not simply outsourcing paperwork.

Can the company start with one product and add others later?

Yes, but every new category should go through classification and product-control review. A previous successful shipment does not approve unrelated goods.

Official references

• Customs: Provisions on the Filing of Customs Declaration Entities, GACC Order No. 253
• China International Trade Single Window
• SAFE: Notice on Further Optimizing the Administration of Trade Foreign Exchange Business
• Ministry of Commerce
• State Taxation Administration