Exporter of Record in China
China is the world’s largest exporter, shipping electronics, machinery, solar panels, electric vehicles, steel, and rare earth products to the United States, EU, ASEAN, and South Korea. Outbound cargo moves through the Port of Shanghai and Port of Ningbo-Zhoushan for sea freight and through Shanghai Pudong International Airport (PVG) for air cargo. To act as a legal Exporter of Record in China, an entity must hold a 统一社会信用代码 (USCC), active 对外贸易经营者备案 (Foreign Trade Operator Filing) with MOFCOM, and GACC export registration. A foreign company without these credentials cannot file the 出口报关单 (Export Customs Declaration) through China’s International Trade Single Window. Exports are zero-rated under China’s VAT Law, with input VAT refundable through the 出口退税 system. The Export Control Law (ECL), effective 1 December 2020, governs controlled goods exports.
Carra Globe acts as your Exporter of Record in China, holding an active USCC, Foreign Trade Operator Filing, and GACC export registration for Single Window filing. Carra Globe manages the 出口报关单 export declaration, MOFCOM dual-use export licence applications, 出口退税 VAT refund documentation, RCEP Form R and CCPIT certificates of origin, NFGA CITES permits, and end-user screening for ECL-controlled goods. For cargo movement, Carra Globe integrates freight forwarding into every third-party EOR China solution by sea and air.
What is an Exporter of Record in China
An Exporter of Record in China is the USCC-registered entity named on the 出口报关单 (Export Customs Declaration) filed through the 中国国际贸易单一窗口 (China International Trade Single Window) under China’s Customs Law (海关法). The General Administration of Customs (GACC, 海关总署) processes all export declarations at Chinese customs offices and verifies export licences at the border. The EOR carries legal responsibility for declaration accuracy, ECL export licence compliance, VAT refund documentation, certificate of origin accuracy, and end-user screening under the ECL. A foreign company without USCC and MOFCOM Foreign Trade Operator Filing cannot access the Single Window to file the export declaration. Read our guide on what is an Exporter of Record before shipping goods from Chinese territory.
Why Foreign Companies Cannot Export from China Without an EOR
China’s International Trade Single Window requires a valid USCC and active Foreign Trade Operator Filing before any export declaration can be submitted. A foreign company without Chinese incorporation holds neither and cannot initiate export clearance at any GACC-supervised customs post. Without an accepted export declaration, GACC cannot issue the clearance confirmation required to load cargo onto vessels or aircraft. Beyond the declaration barrier, MOFCOM issues export licences for dual-use goods, critical minerals, and controlled technology only to USCC-registered entities enrolled in the Foreign Trade Operator system, meaning a foreign company cannot independently obtain licences for goods on China’s 2026 Catalogue of Dual-Use Items and Technologies under MOFCOM and GACC Announcement No. 91 of 2025.
What Carra Globe Manages as Your EOR in China
- 出口报关单 export declaration filing: Carra Globe files the Export Customs Declaration through China’s International Trade Single Window using active USCC and GACC export registration before cargo departs
- MOFCOM dual-use export licence management: Carra Globe submits applications to MOFCOM for dual-use goods, critical minerals, and controlled technology on the 2026 Dual-Use Catalogue
- VAT refund documentation: Carra Globe prepares SAT 出口退税 refund applications to recover input VAT paid on goods and production inputs used in export transactions
- Certificate of origin issuance: Carra Globe issues RCEP Form R for RCEP partner-bound exports and coordinates CCPIT certificates of origin for non-preferential and other preferential trade agreement claims
- ECL end-user screening: Carra Globe screens all consignees against China’s Entity List, Unreliable Entity List, and OFAC/BIS restricted party lists before the export declaration is filed
- NFGA CITES permits: Carra Globe coordinates National Forestry and Grassland Administration (NFGA) wildlife export permits for CITES-listed species
- Re-export controls: Carra Globe confirms whether US-origin components in China-manufactured goods trigger EAR jurisdiction before the export declaration is filed
Common Export Holds & Fines in China: How Carra Globe Protects Your Cargo
The most frequent causes of export holds at Shanghai and Shenzhen follow a consistent pattern: export declaration filed with incorrect HS code, MOFCOM dual-use export licence absent, gallium or germanium export quota not confirmed, RCEP Form R unsigned or rules of origin unsatisfied, VAT refund documentation incomplete, consignee on China Unreliable Entity List, NFGA CITES permit absent, EAR-controlled US-origin components not screened. Every one results in cargo held at the GACC customs post with accumulating port storage charges.
Carra Globe prevents these by verifying compliance before cargo departs: classifying every item against the 2026 Dual-Use Catalogue, confirming critical mineral quota positions, completing multi-list end-user screening, and filing the export declaration only after all MOFCOM authorisations are in place.
China Export Compliance Framework (2026)
Export Declaration System and Customs Authority
GACC (海关总署) governs all outbound customs processing under China’s Customs Law (海关法). Every export declaration is filed through the 中国国际贸易单一窗口 (China International Trade Single Window) using the exporter’s USCC. GACC assigns each shipment a selectivity channel: 4-channel system covering immediate release, documentary review, physical inspection, or X-ray inspection. The official GACC English portal is english.customs.gov.cn. For China import compliance under GACC, see our Importer of Record in China page.
Export Control Law and MOFCOM Dual-Use Controls
VAT Zero-Rating and Export VAT Refund
China’s VAT Law zero-rates all goods exports, meaning exporters charge 0% VAT on export transactions. The exporting entity recovers input VAT paid on goods, materials, and services through China’s 出口退税 (Export VAT Refund) system, administered by SAT (国家税务总局). VAT refund rates vary by product category between 0% and 13%, with the current rates for electronics at 13%, textiles at 13%, steel at 0%, and certain chemical products at rates between 9% and 13%. Exporters must submit refund applications through the Golden Tax System within 12 months of export completion.
Export Duties on Critical Minerals and Raw Materials
China applies export duties to a defined list of commodities under State Council tariff schedules. Current export duties apply to: rare earth compounds and metals at rates between 15% and 25%, graphite products under MOFCOM quota and licence controls effective October 2023, tungsten and molybdenum compounds, and certain ferro-alloys. Exporters must confirm current duty rates and quota positions for their specific HS code before shipment, as MOFCOM and the State Council revise these periodically.
China's Entity List and End-User Screening
The ECL established China’s own end-user control system. MOFCOM maintains the 不可靠实体清单 (Unreliable Entity List) for entities that damage Chinese interests, and a separate 出口管制实体清单 (Export Control Entity List) of end-users subject to enhanced scrutiny. Carra Globe screens all consignees against both Chinese lists as well as BIS Entity List, Denied Persons List, and OFAC SDN list before any export declaration is accepted.
Certificate of Origin and Trade Agreement Compliance
China participates in multiple preferential trade agreements requiring certificates of origin. RCEP Form R covers exports to all 14 other RCEP member states including Japan, South Korea, Australia, and ASEAN nations under the Regional Comprehensive Economic Partnership, in force for China since 1 January 2022. ASEAN-China FTA Form E covers exports to ASEAN members under the China-ASEAN Free Trade Area 3.0 framework. ChAFTA Form CH covers exports to Australia under the China-Australia Free Trade Agreement. CCPIT (中国国际贸易促进委员会) issues non-preferential and general certificates of origin at its offices across China.
Export Documents Required in China
- 出口报关单 (Export Customs Declaration): filed through China’s International Trade Single Window using exporter USCC and GACC export registration
- 增值税专用发票 (VAT Special Invoice): issued by the USCC-registered exporter; required for the 出口退税 VAT refund application
- Commercial invoice (商业发票): full goods description, HS code, declared FOB value in USD, Incoterms, country of origin
- Packing list (装箱单): gross and net weights, dimensions, contents per package
- Bill of Lading (提单) or Airway Bill (空运提单): must match the export declaration in all material particulars
- RCEP Form R or ASEAN-China FTA Form E: preferential tariff claims for RCEP and ASEAN-bound exports
- CCPIT certificate of origin: non-preferential origin certification for markets without an active China FTA
- MOFCOM export licence: dual-use goods, critical minerals, and controlled technology under the 2026 Dual-Use Catalogue
- MOFCOM gallium/germanium/graphite export permit: separate quota and permit required for critical mineral exports under 2023-2025 MOFCOM measures
- NFGA CITES export permit: goods derived from CITES-listed species including certain timber, wildlife products, and medicinal plants
- End-user statement: required for ECL-controlled goods; signed by the overseas end-user confirming final destination and intended use
EOR vs Shipper of Record in China: Key Differences
These are two distinct legal roles under Chinese customs law, and companies that confuse the two face GACC compliance failures and ECL liability.
- Exporter of Record: the USCC-registered entity legally named on the 出口报关单, carrying full liability for declaration accuracy, MOFCOM licence compliance, VAT refund documentation, and ECL end-user obligations
- Shipper of Record: the party identified on the Bill of Lading or Airway Bill as the physical sender of cargo
- Who GACC holds accountable: the EOR, not the Shipper of Record, for every export compliance obligation
- Practical application: a foreign company can appear as Shipper of Record while Carra Globe acts as EOR, maintaining full legal compliance without requiring Chinese entity registration
For companies importing goods into China, see our Importer of Record in China page.
Get in Touch
Carra Globe EOR Services in China
Carra Globe’s China EOR service covers the full export compliance chain from origin to border: Exporter of Record, Importer of Record, Delivered Duty Paid, freight forwarding by sea from Shanghai, Ningbo-Zhoushan, and Shenzhen and by air from PVG and Guangzhou, white glove delivery for high-value electronics, semiconductor equipment, and precision instrument shipments, warehouse logistics at bonded facilities near Shanghai and Shenzhen export hubs, and global trade compliance covering ECL classification, MOFCOM licence management, and end-user screening across 175+ countries.
Carra Globe’s EOR network extends across key export markets: Philippines, Brazil, Colombia, USA, Taiwan, Germany, UAE, Mexico and UK. For China import compliance, see our Importer of Record in China page.
Frequently Asked Questions: Exporting from China
Do I need a Chinese entity to export from China?
Yes. Without a USCC and MOFCOM Foreign Trade Operator Filing you cannot access China’s International Trade Single Window to file the export declaration, and Carra Globe holds both registrations to act as the legal EOR on your behalf.
What is the Export Control Law and does it apply to my goods?
The ECL, effective 1 December 2020, covers dual-use goods, military items, nuclear materials, and related technologies. If your goods appear on the 2026 Dual-Use Catalogue under MOFCOM/GACC Announcement No. 91 of 2025, you need a MOFCOM export licence before GACC will clear the shipment.
How does China's VAT refund system work for exporters?
Exports are zero-rated under China’s VAT Law, with the exporter reclaiming input VAT through SAT’s 出口退税 system at rates between 0% and 13% depending on the product HS code. Refund applications must be submitted within 12 months of export completion through the Golden Tax System.
Do China's export controls on gallium and germanium affect my shipment?
If your goods contain gallium, germanium, graphite, or antimony in any form, MOFCOM licence and quota requirements under measures effective from August 2023 apply before GACC will release the shipment. Carra Globe checks critical mineral content at the classification stage before accepting an export instruction.
How long does export customs clearance take in China?
GACC clears immediate release channel shipments within hours of Single Window submission, documentary review adds 1 to 3 business days, and physical inspection adds 3 to 7 business days. MOFCOM dual-use export licence applications take 10 to 45 business days depending on item sensitivity.
What happens if I export controlled goods from China without a MOFCOM licence?
The ECL authorises MOFCOM to impose fines of up to five times the transaction value and suspend or revoke export qualifications for unlicensed exports. For serious violations the matter can be referred for criminal prosecution under Chinese criminal law.
What is the difference between an EOR and a freight forwarder in China?
A freight forwarder arranges transport but carries no legal liability for export compliance under the ECL or Customs Law. The EOR is the USCC-registered entity named on the 出口报关单 carrying full legal accountability, and Carra Globe acts as EOR while coordinating the forwarder under one structure.
Can a foreign company claim China's export VAT refund?
No. Only USCC-registered entities with VAT general taxpayer status and active Foreign Trade Operator Filing can submit 出口退税 applications through SAT’s Golden Tax System. Carra Globe holds all required registrations and processes VAT refund claims as part of the EOR China service.
Does EAR still apply to US-origin components exported from China?
Yes. If goods manufactured in China incorporate US-origin components with an ECCN above the 25% de minimis threshold, EAR jurisdiction follows those goods out of China regardless of where they were assembled. ITAR applies to US Munitions List items with no de minimis threshold.
What CITES permits are required for China exports?
The National Forestry and Grassland Administration (NFGA, 国家林业和草原局) is China’s CITES Management Authority and issues permits for tiger products, bear bile, certain timber, pangolin products, and CITES-listed medicinal plants. Processing times vary by species classification — contact NFGA directly before scheduling shipment.
