Key points
- The exporter of record must be registered with China Customs; a foreign buyer normally cannot be.
- Buy FOB or FCA rather than EXW so the supplier owns export clearance.
- General trade (code 0110) is needed for the export VAT rebate; Yiwu-style market goods often use 1039.
- Rare earths, magnets, graphite, gallium, germanium and some battery materials need a licence check, and suspended controls were due to expire on 10 and 27 November 2026.
- Vague descriptions, undeclared batteries and untreated wooden pallets are the most common reasons cargo is held.
What export clearance in China involves
Every commercial shipment leaving China is declared to China Customs (GACC). The declaration is filed electronically through the Single Window, which links customs, inspection, tax, foreign exchange and port systems. Customs checks the declared goods, value, HS code and trade mode, runs its risk check, and may inspect the cargo before it releases the container for loading. Without that release the box does not go on the ship.
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Who can be the exporter of record
Since 30 December 2022 China no longer requires the separate foreign trade operator registration with the Ministry of Commerce. The exporter still needs customs registration as a consignor or consignee and an electronic port account. Most factories that export regularly have both. Small workshops and market stalls often do not, and that is where the options below come in.
- Factory is registered with customs and declares in its own name under general trade 0110.
- Lets the supplier claim the export VAT rebate, which keeps its FOB price lower.
- Best match for FOB or FCA terms.
- Invoice, contract and declaration all show the same seller and buyer.
- A licensed trading or supply-chain company declares on the supplier's behalf.
- Can usually handle the VAT rebate for the supplier.
- Useful when a good factory has no export registration.
- Adds a fee; make sure the agent's name and the invoice data are consistent.
- Created in Yiwu in 2013 and extended to about 39 pilot markets.
- Simplified declaration with broader HS groupings; no VAT invoices needed.
- VAT exempt but no rebate; commonly capped at USD 150,000 per declaration.
- Not for licensed, controlled or some inspection-sensitive goods.
The export declaration step by step
- Confirm the HS code and trade modeThe supplier or broker classifies each item to 10 digits and picks the trade mode, usually 0110 general trade or 1039 for market goods.
- Check licences, inspection and controlsThe HS code shows whether an export licence, a statutory inspection (condition B) or a dual-use licence is needed.
- Collect documentsCommercial invoice, packing list, sales contract, declaration authorisation and the declaration elements for every line.
- Book and deliverThe forwarder books space, the container is stuffed at the factory or a consolidation warehouse and delivered to the terminal before the customs cut-off.
- File in the Single WindowThe broker files the declaration electronically; customs runs a risk check.
- Inspection if selectedCustoms may check documents or open the container. Wrong descriptions, brands or hidden batteries are common triggers.
- Release and loadingAfter release the terminal accepts the container for loading and the carrier issues the B/L.
- After shipmentThe supplier collects export proceeds and files its VAT rebate claim; the declaration data must match its VAT invoices.
Documents the broker needs
| Document | What it does | Who provides it |
|---|---|---|
| Commercial invoice | Value, currency, Incoterm and exact goods description per line | Supplier |
| Packing list | Cartons, weights and dimensions; must match the invoice | Supplier |
| Sales contract | Shows the buyer, seller, goods and terms behind the declaration | Supplier and buyer |
| Declaration authorisation (报关委托书) | Authorises the broker to declare for the exporter | Exporter |
| Declaration elements | Material, use, brand, brand type and model for each HS code | Supplier, checked by the broker |
| Licences or e-record numbers | Export licence, dual-use licence, inspection e-record, CITES where relevant | Exporter |
| Brand authorisation letter | Needed when goods carry a third-party brand | Brand owner via supplier |
| DG documents | SDS, UN38.3 for batteries, DG packaging certificate, DG declaration | Supplier and packaging maker |
Before your goods leave the factory
0/9Licences, inspection and restricted goods
- Prohibited exports include certain wildlife and CITES species products, cultural relics and items under UN sanctions.
- The export licence management list published each year by MOFCOM and GACC covers some agricultural products, metals, minerals and chemicals.
- Goods in the compulsory inspection catalogue (supervision condition B) need an export inspection and an e-record number before declaration: for example food, animal and plant products, hazardous chemicals and dangerous goods packaging.
- Lithium batteries need a UN38.3 test summary, SDS, correct UN number and UN packaging; sea shipments follow IMDG Code Amendment 42-24, mandatory from 1 January 2026.
- China Customs enforces trademark rights on exports; suspected counterfeits are detained and can be confiscated.
- Goods made in China must not be labelled with another origin.
Export controls: status as of November 2026
China's Export Control Law (in force 1 December 2020) and the dual-use regulations and list (in force 1 December 2024) require a MOFCOM licence and end-user statements for listed items. Official review can take up to about 45 working days. Ordinary consumer goods with small magnets or standard batteries are generally not licensed items, but suppliers of magnets, motors, battery cells and battery materials should check their HS codes.
| Items | Controlled since | Status as of early November 2026 |
|---|---|---|
| Gallium, germanium and compounds | 1 Aug 2023 | Licence required |
| Certain graphite | 1 Dec 2023 | Licence required |
| Antimony, superhard materials | 15 Sep 2024 | Licence required |
| Tungsten, tellurium, bismuth, molybdenum, indium items | Feb 2025 | Licence required |
| 7 medium and heavy rare earths and related magnets | 4 Apr 2025 | Licence required, never suspended |
| October 2025 expansions: 5 more rare earths, some high-energy lithium batteries, cathode and artificial graphite anode materials | Announced 9 Oct 2025 | Suspended until 10 November 2026 |
| US-specific ban on gallium, germanium, antimony, superhard materials | Dec 2024 | Suspended until 27 November 2026 |
Export VAT rebates and why they change your price
China's standard VAT is 13% (9% or 6% for some goods). An exporter declaring under general trade in its own name can reclaim input VAT at a product-specific rebate rate of 0–13%, provided the declaration matches the manufacturer's VAT special invoice and the export proceeds are collected. The rebate is built into many FOB prices, so when it is cut, prices rise.
| Date | Change | What buyers should expect |
|---|---|---|
| 1 Dec 2024 | Rebates cancelled for aluminium and copper materials; photovoltaic, battery and some mineral products cut from 13% to 9% | First round of price increases |
| 1 Apr 2026 | Rebate cancelled for photovoltaic products; batteries cut from 9% to 6% | Higher FOB prices for solar goods |
| 1 Jan 2027 | Rebate for battery products to be eliminated | Expect battery suppliers to reprice around this date |
Quick check: are you ready to export?
China export clearance quiz
Frequently asked questions
Who is responsible for export customs clearance in China?
Under FOB, FCA, CFR, CIF and the D-terms the supplier is. Under EXW the buyer formally is, but a foreign buyer cannot normally declare in China, so agree FOB or FCA instead.
Does a Chinese supplier need an export licence to export?
Not a general one since 30 December 2022. It needs customs registration as a consignor. Specific goods still need an export licence, dual-use licence or inspection.
How long does China export clearance take?
For correct documents and no inspection, usually within the normal cut-off before the vessel. Inspections, licence checks or wrong declaration elements can add days, and dual-use licences can take weeks.
What is the 1039 trade mode?
Market procurement, a simplified declaration for goods bought in pilot markets such as Yiwu. It needs no VAT invoices, gives no rebate and is commonly capped at USD 150,000 per declaration.
What documents are needed for export customs in China?
Commercial invoice, packing list, sales contract, declaration authorisation and declaration elements per HS code, plus any licence, inspection e-record, brand authorisation or DG documents.
Are China's export controls on rare earths still suspended?
Some expanded controls were suspended only until 10 November 2026 and a US-specific ban until 27 November 2026. As of late October no extension notice was published, so our team checks the status for each order.
Why did my supplier raise prices for solar panels or batteries?
Export VAT rebates were cancelled for photovoltaic products from 1 April 2026, batteries were cut to 6%, and the battery rebate is due to end on 1 January 2027.
Sources
- China International Trade Single Window (declaration platform)
- China Briefing – China cancels foreign trade operator registration
- Henan Provincial Government – China to adjust or cancel export tax rebates for photovoltaic and battery products (Jan 2026)
- Nami Tech Solutions – China export control suspension: November 2026 scenarios
- Environment+Energy Leader – Rare earth truce is extended, but its legal deadlines stand (30 Oct 2026)
- Fastmarkets – China suspends export prohibition on gallium, germanium, antimony, superhard materials to US
- Kerry Logistics – IMDG Code Amendment 42-24 mandatory from 1 January 2026
- China Daily – Ningbo–Yiwu sea-rail service and pre-clearance in Yiwu (Aug 2025)
General information checked on the date shown. Rules and rates change: our team confirms the details for your shipment.