Important Update: New Chinese Export Compliance Requirements Effective October 2025

Transitainer WA wishes to advise clients and partners of significant changes to Chinese export compliance regulations that will directly impact supply chains and cross-border trade.

In response to industry enquiries, the Department of Foreign Affairs and Trade (DFAT) has confirmed that China now requires export licences for a broad range of commodities. Exporters must ensure strict compliance with Chinese export control rules. While DFAT has noted changes introduced since early 2025, it is unable to provide detailed guidance on specific licensing obligations. Businesses are therefore strongly encouraged to seek guidance from a Chinese customs agent, legal professional with expertise in trade law, or your logistics partner Transitainer WA.

Summary of Regulatory Changes

On 25 March 2025, five Chinese government agencies – the State Taxation Administration, Ministry of Finance, Ministry of Commerce, General Administration of Customs, and State Administration for Market Regulation – jointly issued Announcement No. 8 of 2025, which introduced new compliance requirements for exporters:

• Mandatory Tax Registration – Exporters must be registered with Chinese tax authorities before goods can clear customs.
• Ban on Third-Party Declarations – Export declarations under the name of an unrelated company are no longer permitted.
• Dual-Title Documentation – Factories without export licences must still be listed on customs documentation as the “production and sales entity,” alongside a licensed customs broker. Full manufacturer details (name, address, tax ID) must be provided for tax verification.

Compliance Pathways for Factories – To achieve compliance, factories may:

• Update their business registration to include “import & export.”
• Register via China’s Single Window System.
• Complete registration with local tax authorities (including eligibility for export rebates).

Enforcement Timeline

• Transition Period (1 August – 30 September 2025): Exporters should anticipate shipment delays and procedural adjustments.
• Full Enforcement (1 October 2025): Non-compliance may result in significant fines or legal penalties.

Impact on Supply Chains

• Ex-Works (EXW) and Free Carrier (FCA) shipments may face additional risks if shippers do not fully understand their document obligations.
• Delays are possible in late September as new border control procedures are phased in. Shipments rolling from September into October could be affected.
• Non-compliance risks include fines, rejected shipments, and potential legal penalties issued by the Chinese Authorities.

Implications for Suppliers Without Export Licences

Most suppliers already hold the necessary export licences, but for those that do not, compliance will be essential moving forward. Factories unable to secure their own licences have two primary options:

• Update their business registration and tax compliance to meet regulatory requirements.
• Work through a licensed trade agency that can facilitate export on their behalf.

👉 Transitainer WA can assist in this area via our established China partner. We have already been supporting customers whose suppliers do not hold export licences, ensuring compliance and minimising supply chain disruptions.

How Trade Agencies Can Assist

Under this arrangement, a trade agency can act as the official exporter of record. The process typically works as follows:

1. The importer pays the trade agency directly.
2. The supplier issues a VAT invoice to the trade agency.
3. The trade agency pays the supplier.
4. The supplier arranges shipment to the importer.
5. The trade agency handles customs clearance under its company name and applies for any tax rebates, which are then remitted back to the supplier.

This model is already widely used in China for imports and is now expected to become more common for exports under the new regulatory framework.

👉 Transitainer WA, through our China partner, can provide this solution where required.

Recommended Actions

• Review your supply chain – confirm that your suppliers, shippers, and manufacturers are fully prepared for compliance requirements.
• Engage early with suppliers – encourage those without licences to begin the compliance process or consider trade agency partnerships.
• Plan for potential disruptions – especially for shipments scheduled around the September/October transition period.
• Seek tailored advice – from Chinese customs experts, legal advisors, or your logistics partner Transitainer WA.