Regulatory Environment: Customs, Licensing, and Compliance in 2025
Comprehensive guide to China's freight forwarding regulations, customs procedures, licensing requirements, and compliance challenges in 2025.
Regulatory Overview
The regulatory framework covers customs procedures, operational licensing, trade compliance, safety/security rules, both Chinese domestic regulations and destination country requirements.
Freight forwarders must navigate multifaceted regulations while adapting to constant updates from trade tensions, security concerns, and digitization initiatives.
Customs Procedures
China's General Administration of Customs (GAC) introduced streamlined declaration processes to improve efficiency while maintaining oversight.
Exporters must submit preliminary customs declarations with option for advance filing up to 7 days
Forwarder Impact: Requires earlier documentation preparation and improved internal systems for data accuracy
Submit essential info initially, then provide full details within 14 days after goods enter zone
Forwarder Impact: Eases departure pressure but requires diligent follow-up for final declarations
All customs activities must integrate with China's centralized digital platform
Forwarder Impact: Mandatory platform adoption with requirements for system integration
- Accurate HS code classification
- Correct valuation and documentation
- Timely submission of all declarations
- Integration with single-window systems
- Proper handling of restricted/prohibited goods
Licensing Requirements
Operational Requirements
Basic requirement for ocean freight forwarding operations
Minimum Capital
¥5 million registered capitalStaff Requirements
5+ qualified professionals with 3+ years experience
Required Qualifications
Requirements for air freight forwarding business
Minimum Capital
¥3 million registered capitalStaff Requirements
5+ qualified professionals with 3+ years experience
Required Qualifications
Requirements for rail and road freight operations
Minimum Capital
¥2 million registered capitalStaff Requirements
5+ qualified professionals with 3+ years experience
Required Qualifications
Special Permits
Requirement
Ministry of Transport registration with financial guarantee
Applicability
Forwarders issuing house bills of lading for ocean shipping
Process
File company details and financial guarantee with MOT
Requirement
Road Transport Business License
Applicability
Forwarders operating trucking, especially international road transport
Process
Application through transport authorities
Requirement
Registration through China International Trade Single Window
Applicability
Forwarders acting as customs brokers for client declarations
Process
Online registration and qualification verification
Requirement
Special certifications and personnel training
Applicability
Forwarders handling hazardous materials
Process
Safety training and certification programs
Foreign Investment Framework
Liberalization
2019 abolition of restrictions on foreign-invested freight forwarding firms with simplified approval procedures
Current Process
Establishing forwarders (including wholly foreign-owned) mostly requires meeting conditions and filing paperwork rather than discretionary approvals
Trends
Shift toward filing/registration instead of prior approval, aligning with trade facilitation reforms and attracting more foreign investment
Trade Compliance
Forwarders must ensure correct HS code classification, duty calculation, and compliance with varying tariff rates by product category.
Forwarder Responsibilities
- • Monitor constantly changing tariff lists
- • Route shipments through third countries when beneficial
- • Explore tariff engineering opportunities
- • Advise clients on cost impacts and mitigation strategies
- • Handle export tax rebate documentation
- • Arrange duty payments and customs bonds
2025 Challenges
- •Rapidly changing tariff structures due to trade tensions
- •Complex routing decisions to minimize duty impact
- •Increased documentation requirements
- •Client advisory role expansion
China tightened export controls on dual-use and sensitive items including advanced semiconductors, specialized materials, and telecom equipment.
Requirements
- Verify export license requirements for dual-use goods
- Obtain end-user certificates where required
- Check prohibited items lists regularly
- Ensure proper documentation for sensitive technologies
Geopolitical tensions created dual compliance challenge with both foreign sanctions and China's anti-foreign sanctions law.
Key Challenges
- • China's anti-foreign sanctions law penalizes adherence to foreign sanctions against China
- • International sanctions on Russia, Iran affect routing and cargo acceptance
- • Russia-Ukraine conflict disrupted China-Europe rail corridors
- • Russian transit bans on dual-use items caused cargo impoundments
Route Impacts: Many forwarders avoid Russia rail routes for sensitive goods categories due to sanctions complications
Special Regulations
Explosive growth in cross-border e-commerce created new regulatory frameworks for small parcels and direct-to-consumer logistics.
Adaptations Required
- • Use Section 321 consignees in US
- • Set up bonded warehouses in Hong Kong as intermediate points
- • Consolidate shipments differently to reduce per-unit costs
- • Implement new documentation systems for small parcels
China instituted green trade regulations aligning with carbon peaking by 2030 and neutrality by 2060 goals.
Mandatory carbon footprint disclosures for certain imports/exports including cars, solar panels, and other specified goods.
Requirements
- • Submit carbon emissions data for production and transport
- • Integrate with digital customs systems for environmental documentation
- • Assist clients in carbon footprint calculations
- • Ensure compliance to avoid clearance delays
Timeline: Implementation began in 2025 with expansion expected across more product categories
Requirements
- • Proper packaging and documentation for hazardous materials
- • Specialized forwarder certification for hazmat handling
- • Compliance with IATA Dangerous Goods Regulations
- • Chinese civil aviation rules adherence
Compliance: Non-compliance can result in shipping delays, fines, or cargo rejection
Incentive Programs
China's Authorized Economic Operator program certifies freight forwarders and shippers with strong compliance records.
Benefits
Certification
Expanded training and certification for logistics professionals in partnership with customs authorities.
Competitive Advantage
AEO certification and trusted partner status provide significant operational advantages and faster processing
Strategic Advice
- Treat compliance as core competency rather than afterthought
- Invest in digital compliance systems and staff training
- Maintain up-to-date knowledge of regulatory changes
- Develop robust documentation and verification processes
- Build relationships with customs and regulatory authorities
- Implement multiple compliance verification checkpoints
- Maintain current blacklists and restricted entity databases
- Develop contingency routing plans for different scenarios
- Regular legal consultation on complex compliance issues
- Staff training on latest regulatory requirements
Partner Selection: Partner with forwarders who demonstrate deep regulatory knowledge and proactive compliance management to avoid cargo delays and penalties.