China Ends Trading-House Exports from 1 October 2025: What It Means for Your Shipment to Russia

1. What changed in the Chinese rules

Two documents do the work, and they reinforce each other.

• STA Announcement [2025] No. 17 — for agent exports, the full details of the real export principal (the manufacturer or seller in China) and the amount of each declaration must be filed together with the advance corporate income tax return. Name a broker or forwarder instead of the factory, and the agent is deemed a self-exporter and taxed on the corresponding sum. Effective date: 1 October 2025.
• GACC Order No. 277 (in force since 1 May 2025) — tightens the declarant's personal responsibility for the accuracy of the data and makes post-clearance control and end-to-end reconciliation between customs, the tax authority and currency control far easier.

Legal commentary on No. 17 describes it as the de facto end of “buy-order export”: the space for a paper exporter standing between the factory and the foreign buyer has essentially disappeared.

2. Why the trading-house route is closing

The old pattern is familiar to anyone who has sourced in China: a smaller factory sold the goods to a trading house or an agent, and that intermediary filed the export in its own name. The foreign buyer's contract, invoice and export declaration named three different parties, and nobody had to explain the gap.

Now the agent is obliged to disclose the real factory. If it does not, it takes on the tax burden of its own export plus the risk of an audit. Together with Order No. 277, that makes the old scheme both unprofitable and risky for every link in the chain — factory, agent and declarant alike.

This matters to you even if your company is not Chinese. If your goods are manufactured in China, transhipped through China, or bought from a Chinese supplier and resold onward to Russia, the export leg of your shipment now has to be papered in a way that names the real producer. The mirror side of that paperwork lands on your Russian buyer's desk when the goods are declared for import, and it is there that a mismatch turns into a delay. If you want the export and the import leg planned as one job, that is exactly what end-to-end logistics from China and customs clearance in Russia are for.

From 1 October 2025 Chinese export declarations must name the real manufacturer behind the shipment

3. What your buyer in Russia will now ask for

Expect the requests below on your next order — not because your buyer has become difficult, but because the documents have to survive a comparison at two borders.

The single thing that stops a container is a mismatch between the seller in your invoice and the shipper in the export declaration. Russian customs compares the two, and where they disagree the importer gets a request for additional documents and a customs value check — days of storage, not hours.

Two practical consequences for the sender. First, the company name, legal address and USCC on your documents must be identical everywhere, character for character — an abbreviated trading name on the invoice and the full legal name on the declaration is already a discrepancy. Second, product documents follow the same logic: if the manufacturer named in your conformity certificates for the Russian market is not the company selling the goods, your buyer has to explain the relationship before the goods are released.

4. Price and lead time: what to plan for

• Price. Compliance and documentation work costs money, and the “grey discount” that the old route quietly carried is gone. For several product groups the effect is compounded by reduced or withdrawn export VAT rebates and separate export duties on certain HS codes — Beijing cut or cancelled rebates on a range of positions in 2024–2025. How much of this lands in your price depends entirely on your HS code, so it is worth calculating rather than assuming.
• Lead time. The fast shipment arranged by a forwarder without disclosing the factory is no longer available. Reconciliation between tax, customs and currency control makes the process predictable but less flexible: paperwork has to be complete before the booking, not caught up afterwards.
• Routes. The region as a whole is tightening control, and selective transit restrictions appear from time to time along the corridors to Russia and the CIS. Build a buffer into your delivery promise and keep an alternative leg — sea freight or rail — costed in advance.

5. What the exporter should do now

1. Audit your current shipments. Identify which ones move as agent exports and which still go through a trading house. Those are the ones that will break first.
2. Confirm export rights. For every factory you use, obtain the charter documents and the export licence (进出口权), and verify the legal name, address and USCC against what appears on your invoices.
3. Rebuild the contract chain. Update your templates so the factory is the seller and your buyer is the purchaser, with no intermediary inserted in the middle. Where you resell rather than manufacture, agree in writing with your buyer how the chain will be documented.
4. Fix the declaration procedure. The broker must file in the factory's name, not the trading house's. Confirm this with your forwarder before the next booking, in writing.
5. Check the HS code on both sides. Chinese HS and the EAEU code, applicable rates, rebates and any export restrictions — discrepancies here are what turn a routine clearance into an expert examination.
6. Run one pilot shipment. Test the full document set on a single consignment, see what Russian customs asks for, then scale the pattern to the rest of your orders.

6. Frequently asked questions

Can we still export through a forwarder?
Yes — as an agent export with full disclosure of the real principal, meaning the factory. Without that disclosure, the agent is taxed as a self-exporter, and sooner or later that cost or that refusal comes back to you.

Do all goods now need a separate export licence?
No. Licensing applies to controlled categories. For most goods it is enough that the factory holds foreign trade rights and that the declaration is filled in correctly. The answer depends on the HS code, so check it per product rather than per shipment.

Why has our Chinese price gone up?
The grey discount is gone, compliance work has been added, and for some product groups VAT rebates were trimmed or export duties apply. The size of the effect is a calculation against your specific HS code.

What happens if the wrong party is reported?
The agent is assessed tax as a self-exporter, and both sides may face reconciliation and audits. On your side the visible symptom is different: the export declaration your buyer receives names a party that does not match the invoice, and the goods sit at the border while that is explained.

Is this permanent?
The direction of travel is long-term transparency. Synchronised tax, customs and currency control is the new baseline, not a temporary campaign.

Summary

From 1 October 2025 the real manufacturer must be disclosed on every agent export from China, and the simplified route through a trading house is effectively over. For you as the sender this shows up as a different document set: a direct contract with the factory, matching names on the invoice and the export declaration, confirmed export rights and a traceable payment. Build in extra days for the first shipments under the new pattern and check your HS code for rebate and duty changes. Send us a request, and we will go through your specific shipment and the documents your buyer will need at the Russian border.

We will verify your factory's export rights and make sure your export declaration matches the documents your buyer files at Russian customs.

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