Do I need a China export license to export from China?
With Chinese authorities tightening controls on exports based on informal “purchase orders” (also known as “loan orders” or “false declarations”) in 2025, international buyers and small sellers face new compliance and logistics challenges.
This article explains the new services buyers should seek to maintain a stable, compliant, and cost-effective supply chain.
So, before working with a supplier, a key factor to verify is whether they hold a valid Chinese export license. This certification is crucial for legally shipping goods overseas and ensures smoother transactions with customs authorities.
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Do You Need a China Export License to Export from China?
Whether you need a China export license to export goods from China depends on several factors, including who you are (e.g., a foreign buyer, a Chinese company, or a foreign-invested entity in China), the type of goods being exported, and the specific regulations governing those goods.
Below is a clear breakdown to help you understand:
Key Points on China Export License Requirements
1. Who Needs an Export License?
- Chinese Companies or Foreign-Invested Enterprises: If you are a legally registered business in China (e.g., a Wholly Foreign-Owned Enterprise (WFOE) or a Joint Venture (JV)), you must obtain an export license to engage in international trade and export goods from China. This license is issued by China’s Ministry of Commerce (MOFCOM) and is required for customs clearance.
- Foreign Buyers: If you are an overseas buyer purchasing goods from a Chinese supplier, you typically do not need to obtain an export license yourself. The responsibility usually falls on the Chinese supplier or manufacturer to hold a valid export license. However, you must ensure your supplier has one to avoid delays or customs issues.
2. Types of Export Licenses
- General License: Allows companies to export “normal” goods without applying for a license for each shipment. This is suitable for most standard goods within the approved business scope.
- Special License: Required for restricted or controlled goods, such as food, cosmetics, medical products, pharmaceuticals, or hazardous materials. A special license must be applied for per shipment.
- Dual-Use Items License: For goods with potential military and civilian applications (e.g., certain technologies or chemicals), a specific licensing system applies, often with stricter scrutiny.
- Rare Earth Elements License: As of April 2025, exports of specific rare earth elements (e.g., samarium, gadolinium, terbium) require individual licenses for each shipment, with detailed documentation and end-user verification.
3. Goods Requiring Licenses
- Permitted Goods: Most goods are subject to an automatic licensing system, meaning a license is issued upon application, valid for up to six months for multiple shipments.
- Restricted Goods: Items like food, cosmetics, medical devices, or certain technologies (e.g., telemetry coding, encryption software) require special licenses or are subject to quotas.
- Prohibited Goods: Some goods, such as certain technologies listed in China’s Export Prohibited and Restricted Technology Catalog, cannot be exported without government approval.
- U.S. Export Control Considerations: If exporting to the U.S., items on the Commerce Control List (CCL) or those intended for military end-use may require additional U.S. licenses under the Export Administration Regulations (EAR). An End-User Statement from MOFCOM may be needed for items valued over $50,000.
4. Suppliers Without Licenses
Some smaller Chinese manufacturers, especially those producing components, may not have an export license.
In such cases, they rely on third-party trading companies or export agents to handle the licensing process. As a buyer, you may incur additional costs if your supplier uses an agent, so clarify this upfront. Goods from unlicensed suppliers risk being halted at Chinese customs, and payments in CNH or CNY may be blocked by the State Administration of Foreign Exchange (SAFE).
Always verify your supplier’s license through platforms like Alibaba or with a Chinese supplier agent.
5. Using Freight Forwarders with DDP Terms
Many people choose to let freight forwarders handle DDP (Delivered Duty Paid) terms to manage customs clearance and export processes.
Under DDP terms, the seller (or their freight forwarder) takes responsibility for all export documentation, including obtaining the necessary export licenses, and handles customs clearance at both the exporting (China) and importing country.
This simplifies the process for buyers, as the freight forwarder ensures compliance with China’s export regulations, including securing licenses for restricted or special goods.
However, DDP terms may increase costs, as the freight forwarder charges for handling licenses, customs duties, and taxes on the buyer’s behalf.
Always confirm with your freight forwarder whether they are managing the export license and associated fees.
6. Requirements for Obtaining an Export License (for Chinese Entities)
If you are a business in China seeking an export license, you need:
- A legally registered company with the Administration for Industry and Commerce in China.
- A business scope that includes “import/export of goods.”
- Registration with Chinese customs authorities and MOFCOM.
- A corporate bank account for foreign currency transactions.
- For specific goods (e.g., dual-use items or rare earths), additional documentation like end-user profiles and intended application verification is required.
- The application process involves submitting details about the goods (name, specifications, quantity, destination, etc.) and business details (e.g., annual export plan, contracts).
Why New China Custom Declaration are Necessary from 2025?
The enforcement of cross-agency rules—linking customs, tax authorities, commerce regulators and banking—means informal export arrangements that once skirted paperwork and taxes are now high-risk.
Goods can be detained, payment channels frozen, and agents punished. For buyers who historically relied on “buy-order” workflows, the remedy is not to return to risky shortcuts but to adopt new, compliant service models that preserve speed and cost-efficiency while eliminating legal exposure.
Other Service You May Need beside China Custom Declaration Service:
1. Licensed Export Agent / Formal Agent-Export Services
Buyers without Chinese export qualifications should partner with agents that hold legitimate export licenses and full tax and customs registrations. A reputable agent will:
- Provide legal export documents (contracts, commercial invoices, customs declarations)
- Manage tax filings and compliant foreign exchange collection
- Offer transparent fees that reflect the agent’s regulatory responsibilities
2. 1039 Market Procurement Trade Services
The 1039 market procurement model (suitable for single shipments below the regulated threshold) remains a practical solution for small-value, mixed-SKU shipments. Service providers specialized in market procurement can consolidate multiple small sellers under one compliant customs declaration, delivering faster clearance and lower paperwork for buyers of small goods lots.
3. One-Stop Supply Chain Providers
One-stop providers manage procurement, quality control, warehousing, customs clearance and outbound shipping. For buyers who want minimal operational overhead, these providers reduce the chance of noncompliance by ensuring all steps are documented, and by keeping auditable records for customs and tax inspections.
4. Compliance-Focused Freight Forwarders
Freight forwarders that explicitly support compliance will have tightened onboarding processes, require supporting trade documents, and maintain strong relationships with customs and tax authorities. They usually offer:
- Pre-shipment document checks
- Real-time status updates for customs holds
- Advice on harmonized tariff codes and risk mitigation
5. Overseas Warehousing and Distribution
To avoid repeated customs entry and reduce risk per shipment, buyers can ship larger consolidated loads to overseas warehouses. This approach lowers per-shipment compliance overhead, shortens last-mile delivery times, and separates Chinese export risk from final distribution.
6. Trade Finance & Payment Assurance Services
Because fund flows can be frozen when irregularities are suspected, buyers should use documented payment channels and consider trade finance instruments (documentary collections, letters of credit, escrow services) that provide payment assurance while preserving compliance records.
7. Certification, Testing and Pre-Shipment Inspection
Independent inspection and testing services that provide verifiable reports strengthen the documentation chain. These reports are valuable to customs and to buyers who must demonstrate the legitimacy and quality of shipped goods.
Practical checklist for buyers choosing new services
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- Verify the service provider’s export license and tax registration numbers
- Request sample documentation (contracts, invoices, customs declarations) before first shipment
- Use consolidated export models (like 1039) when suitable for small-value, mixed-SKU shipments
- Prefer providers offering full traceability of funds and clear dispute resolution terms
- Budget for slightly higher fees: compliant services often cost more but greatly reduce legal and financial risk
Benefits of switching to compliant services
- Reduced risk of cargo detention, fines, and frozen funds
- Stronger business relationships with trusted Chinese suppliers and service partners
- More predictable lead times and fewer opaque charges
- Better scalability—compliant processes are easier to audit and replicate
