The right to trade, in six registrations
Since the Foreign Trade Law was amended at the end of 2022, the old foreign trade operator filing is gone. What remains is a chain of six registrations — and a company that stops after the first one cannot legally export.
- 6Registrations in the chain
- 1–2 wksTypical completion
- 10 digitsCustoms code you receive
- 0Fee for the customs filing itself
Six steps, in order
Business scope
Add “import and export of goods / technology” to the scope. Without this sentence nothing downstream can be filed. One change filing, 3–5 working days.
Customs registration
File with the Shanghai customs as an import-export goods consignor/consignee through the single window. You receive a 10-digit customs code and become a registered declarant.
E-port card
Apply for the operator IC card and the legal representative card at the China e-port Shanghai data centre. This is what signs declarations electronically.
FX listing
Register on the goods trade foreign exchange revenue and expenditure list at your bank. Without it, export proceeds cannot be settled legally.
Export VAT refund filing
File the refund eligibility record with the tax bureau, choose the refund method, and set up the declaration channel. This is the step that turns export into cash back.
Single window & CIQ
Register on the national single window, and add inspection and quarantine filing if your goods are in the statutory inspection catalogue — food, cosmetics, medical devices, some machinery.
Some goods need more than a licence
| Product | Extra requirement | Where it bites |
|---|---|---|
| General goods | None | Customs code and e-port card are enough |
| Food & beverages | Importer filing, Chinese label filing, CIQ clearance | The first container can sit at the port until labels are approved |
| Cosmetics | Importer filing, product filing or registration | Ordinary cosmetics file; special cosmetics register, which takes months |
| Medical devices | Class I filing, Class II/III registration | Class III registration can take a year — plan before signing supply contracts |
| Children's toys, electronics | CCC certification | No CCC, no clearance, regardless of the licence |
| Books, audio-visual | Content approval | Restricted; usually not viable for a trading company |
“Buying a licence” is not a thing anymore
The 2022 amendment removed the operator filing requirement precisely to lower the barrier. Anyone still charging you for a “foreign trade operator certificate” is selling a document that no longer exists.
What still costs money is the work: the customs record, the e-port card, the FX listing, the refund filing, and knowing which HS code your product belongs to.
Using someone else's import-export qualification to move your own goods — “borrowing the channel” — is the fastest route to a suspension, and the goods are confiscated, not returned.
What the customs desk will ask for
- Licence and chopsBusiness licence with the trade scope, company chop, legal representative ID.
- Bank accountBasic RMB account plus the foreign currency account for settlement.
- Office and warehouseAn address that matches the licence; a bonded or ordinary warehouse if you hold inventory.
- Product informationHS code candidates, product description, intended use. Getting the HS code wrong changes the duty rate and can invalidate the refund.
- Staff contactA named person responsible for declarations, with a phone number the customs can reach.
Trade questions
Can a WFOE export directly?
Do I need a minimum registered capital?
Can I import and sell domestically?
What if I only sell services abroad?
How long does the customs record take?
Start with a 20-minute call
One short reply with a written scope and price. No obligation, no sales sequence.