With China's VAT Law taking effect on January 1, 2026, together with its supporting measures — MOF & STA Notice No. 2026-11 and STA Announcement No. 2026-5 — export-agency business has changed in several practical ways: a 36-month "hard" declaration deadline, a document-retention period extended to 10 years, foreign-exchange (FX) collection materials moved (in most cases) to retain-for-inspection only, and end-to-end paperless processing through the electronic tax bureau and the Single Window. This guide walks through the agency export business across seven stages — choosing the agency model, signing, filing, procurement and customs declaration, FX collection, rebate application, and recordkeeping — and flags exactly where the 2026 rules bite.

1. The First Step Isn't Signing — It's Choosing the Right Agency Model

In practice, export agency takes at least three common forms. They differ completely in contract structure, document flow, and who claims the rebate. Pick the right model first, and the contracts and tax treatment won't end up fighting each other.

  • True agency (pure agency export) — The agent contracts with the overseas buyer in the principal's name (or signs on their behalf), takes no title to the goods, bears no trading risk, and earns an agency or service fee. The rebate claimant is the principal (the manufacturer or trading company); the agent only issues the Certificate of Agency Export of Goods. This is the cleanest form of agency in legal terms.
  • Buy-out export (self-operated export) — The trading company purchases the goods from the manufacturer (obtaining a special VAT invoice), then exports under its own name, bearing both the collection and rebate risk. Here the rebate claimant is the trading company itself, under the exempt-and-refund method. Strictly speaking this is no longer "agency," but it is often what clients mean when they say they want a trading company to "act as their export agent."
  • Comprehensive Foreign Trade Services (CFTS / "waizongfu") — The most widely used model in recent years. A CFTS enterprise provides a bundled service to small and mid-sized manufacturers: agency customs declaration, advancing the rebate, collecting FX on their behalf, logistics financing, and more. Under the new rules, a CFTS firm may collect FX on the client's behalf and provide an RMB receipt as the FX-collection evidence — especially helpful for small factories that have no foreign-currency account.

Warning line: Article 7 of Notice No. 2026-11 makes clear that arrangements such as "exporting in one's own name while in substance operating under another party's name," "signing both a purchase contract and an agency-export contract," or "bearing none of the quality, collection, or rebate risk" will all be taxed as domestic sales. This is the so-called "four-self, three-not-seen" red line, and it remains under close scrutiny in 2026.

2. The Signing Stage: Three Contracts, None Optional

Agency export involves three legal relationships, matched by three contracts that are best drafted together so they cross-reference cleanly:

  • Export sales contract — between the principal (or agent) and the overseas buyer. Key terms: price terms (FOB/CIF), currency, payment method, delivery date, and quality liability.
  • Agency export agreement — between the principal and the agent. Key terms: scope of agency, agency fee, ownership and transfer of the rebate proceeds, FX-collection responsibility, and risk allocation.
  • Customs declaration mandate — between the principal/agent and the customs broker. Key terms: declaration authorization, document handover, and division of responsibility.

Four clauses must be spelled out in the agency agreement: (1) ownership of the rebate — where it belongs to the principal, how many days the agent has to transfer it after receipt; (2) the FX-collection path — whether funds land directly in the principal's account or pass through the agent/CFTS firm; (3) documentation duties — who obtains and retains the special VAT invoice, purchase contract, and transport documents, and for how long; and (4) indemnity — compensation if the tax authority claws back a rebate because the principal supplied false invoices.

3. The Filing Stage: Register for Export Rebate (Exemption) First

Under Article 4 of the 2026 Announcement No. 5 measures, an exporter must complete export rebate (exemption) filing before the first rebate claim or the first request to issue a rebate certificate. The submission includes the Export Rebate (Exemption) Filing Form, the documents listed in the accompanying checklist, and any other materials the competent tax authority requires.

For changes: where filed details change, the exporter must apply to update them within 30 days of the change. Where the rebate method itself changes (between exempt-credit-refund and exempt-and-refund), the prior rebate generally must be settled before applying.

In practice, filings are submitted online through the unified national electronic tax bureau, and the authority registers them once the materials are complete. Note: the measures set no specific turnaround in days — the "three working days" often cited is an empirical figure, not a statutory limit, and varies by locality.

4. Procurement and Customs Declaration: Document Consistency Is the Floor

"Document consistency" runs through the entire agency-export flow. Any mismatch can turn into a "doubtful point" during rebate review and lead to the rebate being temporarily withheld.

  • Domestic procurement — The principal obtains a special VAT invoice; the product name, unit of measure, and quantity on the invoice must match the later customs declaration. Article 23 of the No. 5 measures requires the product name and unit of measure on the declaration and on the purchase voucher to agree. Where multiple components are combined on a single declaration, the exporter must report the correspondence and conversion basis to the competent tax authority in writing.
  • Mandated declaration — The agent signs a customs-declaration mandate with the broker, who declares accordingly. Notice No. 2026-11 draws a red line here: handing export declarations and other rebate vouchers to any party other than the freight forwarder or broker named in the mandate, or a forwarder designated by the overseas importer, results in tax treatment rather than a rebate.
  • Export declaration — For self-declaration, file the export goods declaration (within bonded zones, an outbound-goods record list may be filed). For mandated declaration, the Certificate of Agency Export of Goods is filed — the core document of agency export, issued by the tax authority where the agent is located, and used by the principal to claim the rebate (exemption).
  • Transport documents — Ocean bills of lading, air waybills, rail consignment notes, postal receipts and other carrier documents, together with domestic transport invoices and international forwarding-service invoices borne by the taxpayer, are all filing documents under Article 45.

5. The FX-Collection Stage: The Biggest "Relief" Under the New Rules

Article 49 of the 2026 No. 5 measures makes FX collection markedly friendlier: in the general case, no FX-collection materials need to be submitted when claiming the rebate — the supporting materials are simply retained for inspection.

FX-collection materials still must be submitted in only three situations: (1) where the rebate is claimed after April 30 of the year following the date of export declaration; (2) where the exporter's management category is Category 4; or (3) where the tax authority has found the FX-collection materials to be false or fraudulently used and fewer than 24 months have passed since the date of written notice.

On "deemed FX collection": where FX is not collected within the prescribed period but the case falls within the listed circumstances (such as overseas bankruptcy, or war and other force majeure), retaining the Export Business FX-Collection Status Form and supporting materials allows the collection to be treated as completed. Where the export contract sets a final collection date later than April 30 of the following year, collection must be completed within the contract term and no later than 36 months from the date of export declaration.

Special arrangements for CFTS and cross-border RMB: an RMB receipt may serve as FX-collection evidence in these cases — cross-border RMB trade settlement; mandated export with collection handled by the agent; mandated rebate handling with collection by a CFTS enterprise; and sales settled in RMB to units inside special customs-supervision zones. This gives the CFTS model a clear compliance channel.

6. The Rebate-Application Stage: Three Channels, Four Document Sets

Under Article 41, applications may be filed through any of three free, fully electronic channels: the unified national electronic tax bureau, the standard international-trade "Single Window," and the offline export-rebate filing tool. Forms and vouchers are submitted as electronic data, accompanying materials as imaged or digitized files, and paper materials are bound in application order and retained.

The 2026 "hard" deadline:

  • Normal window — From the month after export declaration through the filing periods up to April 30 of the following year, with FX collected as required.
  • Extended window — Beyond April 30 of the following year, the exporter may still file by completing the vouchers and FX-collection materials within 36 months of the date of export declaration.
  • Consequence of lapse — If no claim is filed within 36 months, the goods are deemed sold domestically, and VAT and consumption tax become payable as domestic sales from the day after the period expires.

Important transition: export business that occurred on or before December 31, 2025 (inclusive) continues under the prior policy and is not subject to the 36-month deemed-domestic-sale rule.

Manufacturer exempt-credit-refund documents (Article 16): the Exempt-Credit-Refund Summary Form, the Manufacturer Export Goods and Repair/Replacement Services Exempt-Credit-Refund Detail Form, the export invoice or ordinary invoice, the export goods declaration or Certificate of Agency Export of Goods, and the materials in the accompanying checklist.

Trading-company exempt-and-refund documents (Article 18): the Trading Company Export Rebate Export Detail Form, the Trading Company Export Rebate Purchase Detail Form, the export goods declaration or Certificate of Agency Export of Goods, and the special VAT invoice or customs import VAT payment receipt.

Review and settlement: once accepted, where the materials are complete and match the administration's electronic data, the authority settles the refund within the prescribed period. If doubtful points arise during review, it may request supplementary materials. The "15–30 working days to disbursement" often heard in practice is an empirical figure, not a statutory limit.

7. Rebate Rates: Don't Forget the April 1, 2026 Watershed

General rule: for goods exported via customs declaration, the applicable rebate rate follows the export date noted on the customs export goods declaration; for non-declaration exports, it follows the issue date of the export invoice or ordinary invoice.

Two major 2026 adjustments (MOF & STA Notice No. 2026-2):

  • Photovoltaic products — From April 1, 2026, the export VAT rebate is abolished.
  • Battery products — From April 1 to December 31, 2026, the rebate rate is cut from 9% to 6%; from January 1, 2027, it is abolished.

For agency business in the PV and battery sectors, an export-declaration date that straddles April 1 means two entirely different sets of books — order scheduling, price terms, and margin calculations all need to be recalibrated. The exact products abolished or reduced are governed by the HS-code lists in the announcement annexes; don't make decisions based on rumors like "the entire PV value chain is abolished" or "ceramic sanitaryware is abolished too."

8. The Recordkeeping Stage: Retain Documents for 10 Years

Article 45 of the No. 5 measures extends the document-retention period from the former 5 years to 10 years. Documents must be organized and retained within 15 days of the rebate claim, and mainly include:

  • Purchase and sales contracts — export contracts, CFTS contracts, trading-company purchase contracts, and the like.
  • Transport documents — ocean bills of lading, air waybills, rail consignment notes, postal receipts, domestic transport invoices, and international forwarding-service invoices.
  • Mandated-declaration documents — the customs-declaration mandate and the agency-declaration service invoice.

Retention format is the exporter's choice — paper, imaged, or digitized are all acceptable. If paper is chosen, the storage location must be noted in the filing-document index. If imaged or digitized, then when the tax authority requires conversion to paper for inspection, the exporter must affix its company seal and sign a statement that the copy matches the original data.

9. High-Frequency Risk Points in Agency Export

To close the loop, here is a "red-line checklist" of the stages that most often go wrong:

  • "Four-self, three-not-seen" — Bringing one's own customer, source of goods, draft, and declaration while never seeing the export product, the manufacturer, or the foreign buyer. Result: treated as taxable, and potentially characterized as rebate fraud.
  • Document inconsistency — Declaration and invoice disagree on product name, quantity, or amount. Result: rebate temporarily withheld pending verification.
  • Overdue, unfiled claims — More than 36 months pass after export declaration without completing the rebate claim. Result: deemed a domestic sale, with VAT and consumption tax payable.
  • FX-collection defects — Neither collecting FX as required nor providing deemed-collection evidence. Result: rebate denied; any rebate already paid must be offset.
  • Handing the declaration to others — Passing the declaration to a non-mandated forwarder/broker or a forwarder not designated by the foreign buyer. Result: tax treatment instead of a rebate.
  • Abnormal transfer of rebate proceeds — The agent withholds or misappropriates rebate proceeds owed to the principal. Result: breach of contract, plus potential tax-law violations.

10. Practical Advice for Both Sides

For the principal (manufacturer or trader): decide your own positioning first — "true agency" versus CFTS dictates the invoice flow, fund flow, and who claims the rebate; spell out the rebate-transfer timing and default liability in the agency agreement; and keep your own ledger even if the agent handles the rebate, tracking each shipment's declaration date, rebate-filing date, and collection date to give early warning of the 36-month limit.

For the agent (trading or CFTS enterprise): hold the "four-self, three-not-seen" line — better to skip a deal than touch borrowed-name exports; make the FX-collection channel and RMB settlement fully compliant, which is core to a CFTS firm's competitiveness; build a 10-year archive on a digital document system rather than stacks of paper; and proactively flag policy changes to principals, especially rebate-rate shifts for PV, battery, and specific HS-code products.

As a licensed customs and export-agency service provider, Zhongshen International Trade can take on the full agency-export workflow — model selection, filing, declaration, FX collection, and rebate application — and keep your documentation aligned with the 2026 rules. Contact our export-rebate desk for a review of your current arrangements.

Disclaimer: this guide is based on MOF & STA Notice No. 2026-11, STA Announcement No. 2026-5, MOF & STA Notice No. 2026-2, and related supporting rules, current as of May 2026. For any specific transaction, the filing scope, declaration basis, rebate rate, and processing timelines are governed by the prevailing source documents and the view of the competent tax authority.