China's new export rules from 1 October 2025: what changes for suppliers shipping to Russia

1. What Announcement No.17 actually changes

Until now an agent could file an export declaration without disclosing who made the goods and at what price they were sold. From 1 October 2025 three data points become mandatory in an agency export: the real producer, the amount of the transaction and the number of the official fapiao invoice.

The consequence of leaving them out is deliberately harsh. The agent is no longer an intermediary in the eyes of the tax authority — it is deemed to have exported the goods on its own account and answers for the tax on the whole value of the consignment. Companies that lived on other people's export quotas lose the economics of that business overnight, which is why the «trading house» and buy-order arrangements are disappearing rather than adapting.

2. Whose shipments this touches

The rule applies to goods leaving mainland China, so it reaches further than Chinese factories alone:

• Manufacturers in China that export through an agent — your company name and your sale price now appear on the declaration.
• Foreign brands and traders that consolidate, assemble or repack in China before shipping on to Russia and the CIS.
• Suppliers who never dealt with the paperwork because an export agent handled it «somehow». That model is the one being closed.

If your goods reach the buyer by road through the Chinese border crossings, the export declaration travels with the truck and is read on both sides — see how the route works for groupage road deliveries from China. The same document then supports customs clearance in Russia, which is where a mismatch becomes visible.

From 1 October 2025 a Chinese export declaration must name the real manufacturer, the transaction amount and the fapiao number

3. Standard or special export declaration

Agree with your buyer, before the goods are booked, which type of export declaration your consignment needs. The choice is not cosmetic: it affects VAT refund on the Chinese side and the strength of the value evidence on the Russian side.

A useful reminder for routing: Hong Kong is a special administrative region with its own customs and tax system, independent of mainland China. Our own warehouse there gives an extra option when the mainland export route needs to be rebuilt — consolidation and onward shipment can be arranged from Hong Kong instead. The whole chain, from pickup to release in Russia, can be taken as a turnkey service.

4. What your buyer in Russia will ask you for

Expect the requests to become more specific and to arrive earlier than before. Your Russian counterparty needs the export declaration to prove the customs value of the goods, and the declaration now has to agree with the rest of your paperwork.

The single most common cause of a hold at the border is a value or a company name in the Chinese export declaration that does not match the commercial invoice and the contract. Prepare the export declaration, the invoice and the fapiao as one consistent set before the truck or container leaves — correcting them afterwards takes days that the cargo spends standing still.

In practice you will be asked to confirm the name of the actual producer, to state the transaction amount exactly as it appears in the contract, and to supply the fapiao number for the sale. If you work through an agent, ask in writing which of you is named as the exporter on the declaration.

5. Steps to take before your next shipment

1. Ask your export agent, in writing, how it will comply with Announcement No.17 and whose name will appear as the exporter.
2. Check that the producer named on the export declaration is the company that actually made the goods.
3. Make sure the transaction amount on the declaration matches your commercial invoice and contract to the cent.
4. Obtain the fapiao and pass its number into the export documents rather than after the fact.
5. Decide with the buyer whether a standard or a special export declaration is required for this cargo, especially for branded goods.
6. Add time to the schedule for the first shipments after 1 October 2025 — agents are rebuilding their processes and paperwork will move more slowly.

6. Frequently asked questions

We are not a Chinese company — does this concern us?
It concerns any goods exported from mainland China, whoever owns them. If your consignment is consolidated, repacked or simply shipped out of China, the declaration for it falls under the new requirements.

What happens if the producer, amount or fapiao number is missing?
The agent is automatically treated as a self-exporter and carries the full tax liability for the whole shipment. That is a strong reason for agents to refuse ambiguous consignments rather than take the risk.

Can we keep working through a trading house?
The schemes that relied on undisclosed producers and buy-order export are what the announcement closes. The export chain has to be built around the real seller and the real transaction value.

Is a special export declaration always better?
No. It costs more and is meant for goods under heightened control, such as well-known brands. For most cargo the standard declaration is the right choice.

Summary

From 1 October 2025 an agency export declaration out of China must name the real producer, the transaction amount and the fapiao number, or the agent becomes liable for the tax on the entire shipment. For you as a supplier this means the export declaration, the invoice and the contract have to tell one and the same story, and your buyer in Russia will start asking for them earlier. Decide in advance whether the cargo needs a standard or a special declaration, and build extra time into the first post-October shipments. Request a consultation and we will go through your particular shipment.

We will check your shipping set of documents against Russian customs requirements and clear the cargo on arrival.

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