Seven documents, three jobs
Exporting from China is not one form. It is seven documents that have to agree with each other. Three prove the sale happened, three translate that sale into customs language, and one says who may sign for you. Miss any of them and the entry never clears.
Transaction documents
Contract, invoice, packing list. They fix what was sold, to whom, at what price and in what packaging. Every number customs reads downstream comes from these three.
Declaration documents
The declaration form, the declaration elements and the filling rules. The form is a summary, the elements carry the product detail, the rules decide whether what you wrote is right.
Authorization document
The customs power of attorney. It names who may file in your name, for which scope, and until when. Without it a broker has no standing to file.
Each document on its own page
Every page follows the same layout: a rebuilt specimen with a numbered badge in each field, then a numbered note for that field covering how to fill it, a worked example, what it has to match, and the mistake that gets it rejected.
The order that avoids rework
Run these out of order and you reissue documents. Load before filing, or issue the invoice after the container is closed, and the whole set has to be redone. Each step produces the input for the next.
Contract and production
Fix product name, quantity, price, delivery window and payment terms in writing.
Invoice and packing list
Issue the invoice, build the packing list, and close the four totals first.
Declaration elements
Pull the element list for the HS code and confirm brand and model against the goods.
Authorization and filing
Sign the power of attorney; the broker files the entry following the filling rules.
Release and settlement
Load, collect the bill of lading, keep the declaration number for the tax refund.
Nine numbers that have to agree
Customs does not read for style. It runs comparisons. These nine groups of fields appear on more than one document, and a single disagreement triggers anything from a rejected entry to a held container.
| Checkpoint | Rule | If it does not match |
|---|---|---|
| Buyer name | Contract buyer = invoice Sold-to = declaration consignee = packing list customer | Four names typed four ways is the single largest source of rejected entries. Copy and paste, never retype. |
| Goods value | Unit price x quantity = invoice amount; sum of items = invoice total = contract value = declaration total | A one-cent gap is a mismatch. Any rounding, conversion or discount needs a paper trail. |
| Packages | Packing list carton count = declaration package count = manifest packages = bill of lading packages | When the three disagree the terminal refuses the container and you refile. |
| Gross and net weight | Packing list G.W. = declaration gross weight; N.W. = net weight; net never exceeds gross | Entering metric tons instead of kilograms multiplies the weight by 1,000 and the manifest match fails. |
| Description and specs | Invoice description = packing list description = declaration goods name = declaration elements | An English invoice and a Chinese declaration are fine, as long as both resolve to the same HS code. |
| Terms of trade | Contract term = invoice term = declaration terms of trade | Declaring FOB on a CIF sale leaves freight and insurance out of the value, which is a misdeclaration. |
| Country chain | Trade country = where the buyer is; destination country = where the port of discharge is; port of destination = that port | A port of destination of "China" next to a destination country of the Netherlands is a broken chain. |
| Reference numbers | Invoice number to packing list; contract number to declaration; bill of lading number to declaration and power of attorney | Reference numbers tie the papers to one shipment. Swap or omit them and the file no longer matches the cargo. |
| Date order | Contract date <= invoice date <= filing date <= export date | Any back-dated document triggers a written explanation during the tax refund review. |
Why declarations come back
These six account for most of the refiling we see at Shenzhen terminals. All of them are catchable before the data leaves your desk.
Buyer named three different ways
Group name on the contract, purchasing entity on the invoice, forwarder on the declaration. The system reads three different buyers.
Port of destination filled in as "China"
The port of destination is the overseas port where the goods are delivered. Filling in China contradicts the destination country on the same page.
Package count or weight differs from the manifest
Totals not added up, metric tons written as kilograms, per-carton weight entered as total weight. The terminal will not load.
Import-only fields filled in
Related-party confirmation, price-influence confirmation and royalty payment are exempt on exports. Copying an import template guarantees errors.
Brand or model does not match the goods
Inspection photographs the carton and the unit. A mismatch is not a correction, it is an escalated inspection and a held container.
Power of attorney omits inspection assistance
Without that box the broker cannot act for you at the inspection bay, and the container waits until you send someone.
Eight questions buyers and exporters actually ask
Who produces the declaration, when it must be filed, what to do when a supplier cannot support it, and how to handle a container built from several suppliers or from online purchases. The answers below reflect current Chinese practice at South China ports; pilot-zone rules vary by district, so confirm the local detail with your broker.
Who issues the China export declaration form?
Nobody hands you a blank one. The declaration is a customs record generated after a filing is accepted and released: your data goes in, the broker transmits it, and customs issues the entry with an 18-digit customs number. The paper copy carries the customs seal; the electronic record is downloadable from the China International Trade Single Window.
Three parties appear on the form. The consignor (domestic shipper) is the company that signs the export contract, holds the import-export license and answers for the filing. The declaring entity is the broker that keys in and transmits the data. The production or sales unit is the factory that supplied the goods.
So only two parties can produce the form: you, filing in your own name, or an agent filing on your behalf — an integrated foreign trade service company, a market procurement agent, or a cross-border e-commerce service provider. A supplier, a buyer or a freight forwarder cannot issue one. What they give you is the invoice, the packing list and the product data.
When does the export declaration have to be filed?
Before the ship sails. China clears exports before loading, not after departure. A declaration filed once the vessel has left is an omission, and there is no retroactive fix.
The practical trigger is a confirmed booking with manifest data in hand: vessel and voyage, bill of lading number, container number, terminal. By sea, release normally has to be in place 24 to 48 hours before the closing cut-off; at Shekou and Yantian the working practice is to clear the day before the container gates in, which leaves room for an inspection. By air, file one day before departure. If the cargo needs commodity inspection, an export license, a dangerous goods packing certificate or a certificate of origin, obtain those first and start two to three days earlier.
Some customs districts accept advance filing: declare while the cargo is still on the road, and the container releases automatically when it gates in. That only works when the manifest is already transmitted and the description, package count and weight are exact — an advance filing cannot be edited after the truck arrives.
The export date on the form is written back from the manifest, not typed by hand. Tax refund, foreign exchange and final closing all key off that date.
How does an exporter obtain the declaration form?
Three things have to be in place: an import-export business scope on the business license, customs registration as a declaring entity (through the single-window enterprise qualification module or the multi-certificate integration channel) giving a 10-digit customs registration code, and an e-port account with single-window access for the legal representative and the operator.
Per shipment you then authorize a broker through the single-window agency mandate, or sign a paper power of attorney, and hand over the commercial invoice, packing list, contract, declaration elements and manifest details. Once the entry is released you download it from the declaration query screen; the tax refund data is pushed to the tax authority automatically, and the paper refund copy was retired years ago.
Without an import-export license there are three legitimate routes: an integrated foreign trade service company files and claims the refund on your behalf; market procurement trade (1039) covers goods bought in a pilot wholesale market; cross-border e-commerce modes 9710 and 9810 cover online B2B and overseas warehouse shipments, provided the company is registered in a comprehensive pilot zone.
What does not work is buying an entry — using another company's name to declare your cargo. The consignor on that form is not you, so no refund reaches you, the foreign exchange does not match, and if customs traces it the case is treated as filing under a borrowed name. The cargo also has no lawful origin on paper.
Who files the export declaration with customs?
Legally, the consignor. China Customs Law requires the exporter of the goods to declare truthfully, and a broker acting under mandate files in the consignor's name. If the data is wrong, the penalty falls on the consignor; the broker can be pursued for the keying error, but the responsible party does not change.
In practice a licensed broker keys and transmits. The broker checks the entry against the filling rules before sending, and carries responsibility for transcription errors. Larger exporters can file in-house with their own registered declarant and skip the broker entirely.
The form shows the split: your company in the consignor field, the broker in the declaring entity field with its customs seal.
Four data sets always come from you and stay your responsibility — HS code and declaration elements, transaction value and terms of trade, package count and both weights, brand and model. A broker does not classify your product for you and cannot vouch for the cargo.
The supplier cannot provide a declaration — how do I export legally?
Start by naming what is actually missing. A declaration only exists after a filing, so a supplier never had one to give. What is usually absent is one of three things: a VAT invoice, an export license, or the filing data (HS code, material, function, brand, model).
- Licensed exporter, supplier issues a VAT invoice. Export in your own name and claim the refund. Cleanest route.
- No license, or no invoice. An integrated foreign trade service company files as the declaring entity and handles the refund, provided the transaction is real and the input invoices exist.
- Small consumer goods, many SKUs, no invoices. Market procurement trade (1039): buy inside a pilot market such as Yiwu, Guangzhou Huadu or Changshu, keep each declaration under USD 150,000, export through a designated port, and settle foreign exchange through an individual account. Exempt from VAT, no refund claimed.
- Marketplace orders. Cross-border e-commerce: 9610 for consolidated retail parcels, 9710 for online B2B, 9810 for overseas warehouse stock. Sellers registered in a comprehensive pilot zone can be exempt on VAT without input invoices.
What to avoid is buying a declaration, borrowing an export name, or asking a forwarder to "handle the paperwork" without a legal filing. The cost is not a small tax bill: no refund, foreign exchange that cannot be banked, and a finding of filing under a borrowed name plus skipped inspection if customs traces the shipment. The cargo also has no documented origin.
If goods have already sailed without a filing, the remedy depends on timing: return the cargo and re-export where that is still possible, or disclose the situation to customs and accept the penalty. A voluntary disclosure is handled more lightly than a mismatch found by the system.
Is the shipper on the declaration the same as the shipper on the bill of lading?
Not necessarily, field by field. The consignor on the declaration is the party that files and claims the tax refund. The shipper on the bill of lading is a party to the contract of carriage. They can differ.
Three common patterns: a factory exporting and booking its own space appears in both places; a forwarder books and issues the master bill, so the shipper is the forwarder or the NVOCC while the declaration names the actual exporter; in a triangular trade the shipper is the intermediary.
Customs matches declaration against manifest on bill of lading number, container number, package count, weight and description. Shipper name is not compared letter by letter, but the relationship must be explainable — keep the booking instruction and the agency agreement on file.
What must line up is the refund and settlement chain. Whoever appears as consignor is the exporter of record: that party receives the payment and claims the refund. Put another company's name on the bill of lading, let the money land in its account, and the refund will not reach you.
At destination, the importing authority reads the exporter from the invoice and the certificate of origin. When those differ from the bill of lading shipper, expect a request for an explanation. The simplest structure points all three at the same legal entity.
One container, several suppliers — does each supplier need its own declaration?
No. One declaration has exactly one consignor. Several suppliers shipping to the same exporter are consolidated into a single entry filed by that exporter.
Break the entry into line items by product and by supplier. A declaration allows up to 20 goods items; beyond that, split into several declarations, and it is normal for one container to correspond to more than one entry.
What each supplier provides is data, not a declaration: a VAT invoice, a packing list split by supplier, and the declaration elements (product name, material, function, brand, model, HS code), plus any required certification or brand authorization.
If each supplier exports in its own name, they file separately and each takes its own house bill of lading; the consolidator stuffs the box and transmits the manifest. Each exporter claims its own refund.
For a consolidated entry, one declaration may sit behind several input invoices. Product name, quantity and amount on each invoice have to line up item by item with the declaration, or the refund verification fails.
Mixing is where inspections go wrong. Cartons not numbered by supplier, shipping marks that do not distinguish owners, and no photo record leave you unable to prove which cargo belongs to which line item. Number the cartons by supplier and photograph the loading.
Buying from 1688, Taobao, JD or a wholesale market — how do I declare it?
The constraint is consistent: most sellers on these channels do not issue VAT invoices, hold no export license, and branded goods come without authorization.
- Market procurement trade (1039). Buy inside a pilot wholesale market and file through a market procurement agent: VAT-exempt, no refund, foreign exchange allowed through an individual account. Built for small consumer goods, many SKUs and consolidated boxes. The cargo must be purchased in the pilot market and leave through a designated port, under USD 150,000 per declaration.
- Cross-border e-commerce. 9610 for marketplace parcels under list-based release, 9710 for online B2B, 9810 for overseas warehouse replenishment. Sellers registered in a comprehensive pilot zone can be VAT-exempt without input invoices.
- Integrated foreign trade service company. Consolidate scattered purchases under one service provider that files and settles. Real transaction evidence is required; without input invoices you get exemption, not a refund.
- Register an export license and ask the seller for an invoice. Plenty of 1688 suppliers can issue a VAT special invoice if you ask before ordering. Accumulate a full shipment, export in your own name, claim the refund. Usually the best net outcome.
Keep the purchase trail: order screenshots, payment records, the seller's dispatch note and the courier waybill. At an inspection these are what prove the cargo came from a lawful source.
Two places shipments fail. Branded goods without a letter of authorization are seized as infringing. Products requiring CCC certification or an energy label often ship without one from online sellers — check before you book, not after the container is held.
What this set is based on
Source
The field notes and specimen layouts follow the General Administration of Customs filling rules for the export declaration (in force since August 2018) and the document formats used in South China trade. The 45 rule clauses are reproduced without paraphrase.
Currency of the rules
Customs district codes, supervision mode codes and declaration element catalogs change by announcement. For an actual filing, use the values published in the China International Trade Single Window and confirm with the competent customs district.
Need the export paperwork handled for you?
Goodhope Freight files export declarations at Shekou, Yantian, Chiwan, Mawan and Dachan Bay every working day. Send us the invoice, packing list and product details — we check them against customs requirements before filing, so a rejected entry does not cost you a sailing.