Importing and Exporting in China: Market-Entry Guide

Start with the trade model, not the form

Before asking which filing is required, define the transaction:

• What goods move, in which direction and under which commercial terms?
• Which entity buys and sells the goods?
• Who is the import consignee or export consignor?
• Will a customs broker be appointed?
• Who owns the inventory and bears commercial risk?
• Which party holds any product- or sector-specific approval?
• Where are customer and supplier payments received?
• Which bank and currency flows support the transaction?
• Who retains contracts, invoices, transport documents and customs evidence?

If these roles are not assigned, the business is not yet ready for a procedure checklist.

Does the China entity need import/export capability?

Treat this as a scoped operating question, not a universal yes/no rule.

The company's business licence states its business scope. The accepted registration rule requires the scope to comply with the market-access negative list and applicable foreign-investment access measures; registration is refused when a pre-registration licensed item lacks the required approval.

The foreign-investment framework applies pre-establishment national treatment together with the negative-list system, and fields outside the negative list are administered under the stated equal-treatment principle.

Those general rules support an early decision gate: compare the planned goods and activities with the intended entity's scope and access position. They do not establish a procedure for a named product or sector. Product- and sector-specific approvals remain deliberately excluded.

Do not use a stale foreign-trade filing checklist

The former statutory requirement for foreign trade operators to file registration with commerce authorities was deleted by the NPC decision of 30 December 2022. The canonical record therefore marks pre-2023 checklists that say this filing is universally required as outdated.

The accepted current boundary also states that relevant departments no longer require those foreign-trade-operator filing materials when market entities apply for the listed import/export licences, quotas or state-trading qualifications.

This does not mean that every other registration, licence, customs or product requirement disappeared. It means the operating team must separate the deleted legacy filing from the current requirements that actually apply to the transaction.

Map the customs roles

Under the accepted GACC rule, a customs declaration is submitted by the import consignee, export consignor or an entrusted customs broker together with accompanying documents. The consignee or consignor may self-declare or appoint a broker, and the declarant must first complete Customs filing.

The same rule uses electronic-data customs declarations except where Customs agrees to paper form in special circumstances.

The consignee, consignor or entrusted broker must declare truthfully and bears responsibility for the truthfulness, accuracy, completeness and standardization of the declared content.

These facts create three management questions:

1. Who owns the underlying product, transaction and document data?
2. Who prepares or transmits the declaration?
3. Who checks that commercial, logistics and customs records agree?

Appointing a broker does not remove the need to allocate internal evidence and review responsibilities. This guide does not state a fixed document list because the applicable documents depend on the goods, transaction and current customs requirements.

Connect trade to banking and foreign exchange

The accepted SAFE rule states that an enterprise carrying out goods-trade foreign-exchange receipts or payments must complete name-list registration with a domestic bank before its first such receipt or payment.

The canonical record also states that, from 1 June 2024, this name-list registration has been handled directly by domestic banks rather than SAFE branches.

Build the trade-FX workstream into the operating model. Identify the receiving and paying entity, bank account, currency, invoice and customs evidence, exceptions requiring review and the owner of bank follow-up. Do not assume the customs flow and payment flow will reconcile automatically.

Use the China tax and operating model guide to connect the trade flow to invoicing, accounting records, VAT assumptions, capital use and profit planning.

Decide whether to operate directly or through a partner

A distributor or local partner can be considered as an operating-model option, but “use a partner” is not a complete answer.

Direct entity-led model

Examine this model when the company expects to control customer contracts, pricing, inventory, importer/exporter roles, local staff or long-term compliance directly. Confirm the actual scope and approval requirements before relying on the model.

Distributor or partner-led model

Examine this model when another party may contract, hold inventory, import or distribute within a clearly defined arrangement. Test control over pricing, customer data, brand, inventory, product compliance and exit/transition.

Outsourced customs or logistics execution

Examine this as an execution layer, not automatically as a substitute for the contracting party, consignee, consignor or approval holder. Record the exact responsibility of the customs broker, freight forwarder, warehouse and internal trade owner.

These are commercial planning models, not legal classifications or claims that a particular route is available for every product.

Build a role-assignment matrix

Create one row for each major trade responsibility and assign the proposed owner, reviewer, evidence source and exception path.

Suggested rows include:

• customer and supplier contracting;
• product master data and description;
• pricing and commercial terms;
• product/sector approval question;
• import consignee or export consignor role;
• customs broker instruction;
• transport and warehouse coordination;
• inventory ownership and reconciliation;
• declaration data preparation and review;
• invoice and payment evidence;
• trade-FX name-list verification;
• bank query response;
• accounting and tax reconciliation;
• returns, repairs, samples and rejected-goods escalation.

Do not assign several parties as “responsible” without naming the final accountable owner. A broker may transmit declaration data, a logistics provider may move goods and an internal team may own the commercial records; the matrix should show how those handoffs are checked.

For a distributor model, add columns for access to customer data, control of pricing, inventory risk, product compliance, brand use, reporting and exit/transition. The aim is to make the commercial trade-offs visible before a contract is signed.

Prepare the handoff pack before execution

A build-ready trade model should contain:

• defined goods and direction of movement;
• draft commercial flow and counterparties;
• proposed contracting, consignee/consignor and broker roles;
• business-scope and general market-access screen;
• list of named products or sectors requiring bounded review;
• logistics, warehouse and inventory map;
• customs-data and evidence ownership;
• bank and trade-FX dependency map;
• invoice, accounting and tax interfaces;
• exception scenarios and escalation owners;
• currentness date for each regulatory or operational claim;
• a clear split between decision work and provider execution.

This pack does not replace the current procedural checklist for a defined shipment. It supplies the facts and ownership needed to create that checklist later.

Before execution, run a tabletop review using one representative shipment and one exception. Ask each owner to explain the contract, goods description, role, declaration data, transport record, invoice, payment and accounting evidence they expect to receive. If two parties assume the other owns the same decision—or no one owns an exception—the model needs revision before a procedural checklist is approved.

Repeat the review when the goods, route, customs site, counterparty, currency, partner or responsible entity changes. A process that is appropriate for one defined flow should not be presented as a universal China import/export process.

The operating pieces to align

Business and market-access scope

Confirm the intended goods, activities, entity scope and any pre-registration approval boundary. If a named product or sector may change the answer, open a separate bounded factual review instead of generalizing from another industry.

Contract and Incoterm assumptions

Document who buys, sells, carries risk, arranges transport and bears each cost. Contract terms should align with the accounting, customs and payment records. This guide does not prescribe an Incoterm.

Customs declaration and evidence

Assign consignee/consignor and broker roles, data ownership, classification review, document preparation and final reconciliation.

Trade FX and banking

Map the receipt/payment path, bank relationship, name-list status, transaction evidence and exceptions requiring bank review.

Logistics and physical control

Map transport, warehousing, inventory, delivery, returns and damage/shortage escalation. Do not confuse physical movement with the legal and customs roles recorded for the transaction.

Tax and accounting

Map invoices, import taxes, VAT assumptions, costs, inventory accounting and evidence ownership into the broader operating model. Specific tax treatment requires transaction-specific review.

A trade-readiness sequence

Step 1: Define the goods and commercial flow

Record product, direction, counterparties, contract, price, currency and expected movement.

Step 2: Allocate operating roles

Name the contracting party, seller/buyer, consignee/consignor, broker, logistics provider, inventory owner and evidence owner.

Step 3: Screen market access and business scope

Apply the general foreign-investment and business-scope boundaries. Split any named product/sector question into a bounded review.

Step 4: Validate current customs and trade-FX requirements

Use current official rules for the actual transaction. Do not reuse a historic filing or a pilot procedure from a different customs site.

Step 5: Align documents and systems

Ensure contracts, orders, invoices, packing and transport data, customs information, bank evidence and accounting records can be reconciled.

Step 6: Test exceptions

Model returns, samples, repairs, rejected goods, price adjustments, multi-party payments and other non-standard flows separately. This page does not state their regulatory treatment.

Step 7: Move to execution only after the model is coherent

Create a current requirements list for the defined goods, route, customs site, entity and payment flow. Then assign execution owners.

Risks and limitations

• Assuming every business needs the same import/export procedure.
• Treating the deleted foreign-trade-operator filing as a current universal requirement.
• Assuming the broker owns the accuracy of all underlying commercial data.
• Mixing importer/exporter, customs broker, freight forwarder and logistics-provider roles.
• Adding a fixed processing timeline without a current, scoped source.
• Generalizing a named customs pilot to the whole country.
• Treating product or sector approvals as covered by a general business-scope rule.
• Designing customs and banking workstreams separately from tax and accounting.
• Routing readers to a service provider before the trade model is defined.

Import/export readiness checklist

• Goods and direction of trade defined
• Contracting parties and currencies mapped
• Import consignee/export consignor identified
• Customs broker role defined
• Business scope and general market-access screen completed
• Product/sector questions separated for bounded review
• Legacy filing assumptions removed
• Trade-FX name-list status assigned for verification
• Bank, customs and accounting evidence mapped
• Logistics and inventory owners named
• Exceptions and returns mapped separately
• Currentness owner assigned before implementation

Frequently asked questions

Does every China company need a foreign-trade-operator filing?

No universal pre-2023 filing statement should be reused. The former statutory commerce-authority filing requirement was deleted, and the current process must be checked for the actual licence, quota, qualification, customs and transaction context.

Can a company appoint a customs broker?

The accepted GACC rule allows an import consignee or export consignor to self-declare or appoint an entrusted customs broker, with the declarant completing Customs filing first. The company should still define who owns the commercial data, supporting documents and reconciliation.

Is customs declaration always electronic?

The accepted rule uses electronic-data customs declarations, while Customs may agree to paper form in special circumstances. Confirm the current operational requirements for the relevant customs site and transaction.

How does trade FX connect to the import/export process?

Goods-trade receipts and payments have a name-list registration dependency under the accepted SAFE claim, handled through domestic banks under the current canonical boundary. Map that dependency alongside contracts, customs evidence, invoices and bank records.

When should a distributor or local partner be considered?

Consider the model when another party may take defined contracting, inventory, importing or distribution responsibilities. Compare control, evidence, customer ownership, product approvals and exit/transition before choosing it. This is a commercial decision framework, not a claim that the route eliminates entity or regulatory requirements.

Related decision guides

• China market-entry strategy
• Review the China tax and operating model