At Australian Customs Brokers and Logistics, one of the most disruptive “new” delay
patterns we’ve been managing is cargo that’s ready to ship—then stalls before it
even departs China because the exporter can’t clear Chinese Customs under the
tightened compliance settings.
From an Australian importer’s perspective, it can look like “the forwarder is slow” or
“port congestion.” In reality, it’s often a documentation + exporter-of-record eligibility
problem at origin: the supplier (or the party trying to export on their behalf) isn’t
correctly registered and therefore can’t produce the export declaration and
supporting paperwork China Customs now expects.

Below is what’s changed, what it means for importers, and the exact due diligence
we recommend before you confirm your next PO.

What changed: exporter registration and “no more third-party exporting”
Multiple freight and compliance advisories have flagged China’s strengthened export
compliance requirements, introduced via a multi-agency announcement and fully
enforced from 1 October 2025 (with a transition period 1 August–30 September
2025).

The practical impacts we’re seeing fall into three buckets:
1) Exporter registration is now mandatory (tax + export compliance alignment)
Exporters shipping goods subject to VAT/consumption tax must be appropriately
registered with Chinese tax authorities before goods can clear export customs
procedures.
2) Ban on “third-party declarations”
Historically, some factories that lacked export capability relied on an unrelated
company to export under that company’s name/licence. That workaround is now
explicitly restricted—export declarations under an unrelated company’s name are no
longer permitted in the way many supply chains previously operated.
3) “Dual-title” disclosure when a factory can’t export directly
Where a factory doesn’t hold its own export licence/capability, the documentation
may need to disclose both:
 the licensed exporter/broker (exporting entity), and
 the manufacturer’s legal details (name, address, tax ID) as the
production/sales entity for tax verification.

Bottom line: for many importers, “my supplier will handle export” is no longer safe to
assume. You must verify that the exporter-of-record is legitimate, registered, and
able to generate compliant export documentation.

What this means for Australian importers
When the exporter side isn’t compliant, we typically see one or more of the following:
 Origin delays: cargo can’t clear export customs in China due to
missing/incorrect exporter registration or documentation mismatches.
 Document sets that don’t reconcile: commercial invoice/packing list issued
by Factory A, but export declaration shows Trading Co B (or vice versa),
triggering questions and rework.
 Risk increases under EXW/FCA: where the buyer controls export clearance
(or relies on a third party), the chain is more exposed if the exporter-of-record
arrangements aren’t clean.

For Australia-side clearance, inconsistent supplier/exporter documentation also
increases the likelihood of ABF/DAFF queries—because the commercial story and
compliance story don’t match. (This is particularly painful if you’re also claiming FTA
preference and need consistent origin/producer/exporter evidence.)

Our recommended due diligence

Before you confirm production (or at least before cargo is packed), request a
compliance pack that includes:
A) “Can you export?” proof set
Ask your supplier for:
1. Business licence showing the business scope includes “import & export”

2. Exporter registration evidence (e.g., China Single Window registration
status)
3. Tax registration/VAT ID evidence relevant to export clearance requirements
If your supplier uses an agent/export company, you need to confirm the agent
arrangement is compliant under the new rules, and that dual-title disclosure
requirements are satisfied where applicable.

B) “Can you produce export documentation?” proof set
At minimum, ensure they can provide:
 Commercial invoice (accurate descriptions, Incoterms, currency, seller/buyer
entities)
 Packing list (weights, cartons, dimensions, marks)
 Export declaration / customs export clearance evidence (as applicable)
 Certificate of Origin (if you need it for FTA claims or documentary
requirements)
 Commodity-specific documents (e.g., MSDS, compliance certificates,
treatment/fumigation where relevant)
AUSCUS can advise you on the Australia-side documentation you’ll need for
clearance depending on commodity, mode, and risk profile (customs, tariff, and
quarantine).

Red flags we’d treat as “stop and check now”
If any of these show up, pause and escalate before cargo moves:
 Supplier says: “We don’t export—our friend company will do it” (without formal
compliant structure)
 Export documents show a completely unrelated exporter with no disclosed
manufacturer details
 Supplier refuses to share export registration/tax registration evidence

 You’re buying EXW, but no one can clearly explain who the exporter-of-record
will be and what documents you will receive
These are the situations that most often turn into late-stage delays or “paperwork
rebuilds” while the cargo sits.

Practical procurement guidance: align Incoterms with export capability
If you’re sourcing from China and you’re not 100% confident in exporter compliance,
structure your purchase terms accordingly:
 Prefer FOB/CFR/CIF (or similar) where the supplier/exporter manages origin-
side export clearance
 Be cautious with EXW/FCA unless you have a proven exporter-of-record
process with compliant documentation controls
This is less about “freight preference” and more about who owns origin
compliance risk under the new China settings.

What to do if your supplier can’t comply
You generally have three options:
1. Move to a supplier that can export directly (cleanest long-term outcome)
2. Use a compliant export/trade agency structure (where the exporter-of-
record is legitimate and documentation requirements are satisfied)
3. Re-paper the transaction so the commercial seller and the exporter-of-
record arrangement are coherent and defensible (often requires careful
handling to avoid downstream audit risk)
The correct option depends on your commodity, value, shipment frequency, and how
sensitive your supply chain is to origin-side delay.

How AUSCUS can help
Because AUSCUS provides customs and quarantine clearance, tariff and trade
consultancy, and freight forwarding/logistics, we can support a practical “pre-
lodgement” approach: verifying supplier documentation capability, aligning Incoterms
and exporter-of-record logic, and ensuring your document set will stand up both at
origin and on arrival in Australia.
If you want, send us:
 supplier name and invoice draft
 Incoterms
 product list (with HS guidance if available)
 your target ship date
…and we’ll tell you what documents we need, what risks we see, and what to fix
before cargo is handed to a forwarder.