Import RepresentationTriple Certification System for Qualifications

According to the latest revision of the "import and exportMeasures for the Record-filing Administration of Consignors and Consignees of GoodsEquipment ImportsThe agent must possess bothBasic qualifications, industry permits, and special equipment filingThree major certification systems. The absence of any one will result in the equipment being detained at the port, incurring a daily late declaration fee of 0.3‰.

Basic Qualification Thresholds

• Import and export operation rights: A business license issued by the market regulatory authorities (with the scope of business including import and export of goods) must be provided.
• Industry certification: AEO-certified enterprises are eligible for expedited customs clearance.
• Registration with the State Administration of Foreign Exchange: Possesses cross-border payment business qualification code
• VAT General Taxpayer Qualification: Essential documents required for equipment import tax rebate

Special Requirements for Equipment Import

• Special Equipment: A special equipment manufacturing license (TS certification) and a safety performance commitment letter are required.
• Medical Equipment: Must cooperate with the importing enterprise to handle the "Medical Device Registration Certificate" and business filing credentials.
• Second - hand equipment: Starting from 2025, mandatory pre-shipment inspection and quarantine certificates will be required (with the addition of an X-ray machine inspection module).

2025 policy outlook

• Customs will establish a database of equipment parameters, requiring agency companies to upload 3D structural diagrams of the equipment.
• The validity period of the import license has been shortened from 6 months to 3 months.
• The import of used mechanical and electrical products requires the submission of a carbon emission assessment report.

Four-Step Method for Qualification Verification

• Step 1: Verification of Original Documents
  • Verify the consistency between the customs registration number and the National Enterprise Credit Information Publicity System.
  • The AEO certification status can be verified on the official website of the General Administration of Customs.
• Step 2: Cross-verification of industry licenses
  • Medical device agents must verify the record of the third-party platform for online medical device trading services with the Medical Products Administration.
• Step 3: Special Equipment Filing Random Inspection
  • Randomly select 3 historical import documents for reverse tracing of the filing process.
• Step 4: Risk Deposit Review
  • Verify whether the proxy enterprise has established an emergency deposit of no less than 15% of the contract amount.

Common Cognitive Biases

• Misconception 1: "All-inclusive service" equals full qualifications (there may actually be cases of borrowed qualifications).
• Misconception 2: Single-window filing can replace special permits (electromechanical equipment still requires separate filing).
• Misconception 3:3CThe certification shall be handled by the agent (must be applied for by the equipment manufacturer).

A case involving the import of precision instruments revealed that due to the absence of a "Pre-shipment Inspection Certificate for Used Mechanical and Electrical Products" by the agency company, semiconductor equipment worth 12 million yuan was detained at the port for 27 days, resulting in additional costs amounting to 860,000 yuan. This case highlights the importance of qualification reviews. It is recommended that enterprises, before signing agency agreements, must request the other party to provide complete original qualification documents and verify them through the official website of the General Administration of Customs.Enterprise Qualification Verification SystemPerform triple verification.