Perspective on core changes in 2025 agency terms

According to Announcement No. 48 of the General Administration of Customs, the import equipment agency business will undergo three major adjustments:

• Customs classification rule updates:
  • Composite function equipment adopts the principle of primary function priority
  • Intelligent module components require separate value declaration
• Pre-shipment certification procedures:
  • Category IIMedical EquipmentMandatory implementation of pre-shipment compliance verification
  • Industrial equipment safety protection level certification scope expanded to 13 categories
• Agency liability boundary restructuring:
  • Declaration error accountability period extended to 36 months after cargo release
  • Quality disputes introduce technical feasibility exemption clauses

Key points for risk prevention system construction

It is recommended to establish triple protection mechanisms in agency agreements:

• Pre-classification dispute resolution:
  • Require suppliers to provide functional module breakdown descriptions
  • Recommend reserving 5% tariff deposit
• Technical compliance review closed-loop:
  • Establish a mapping database between equipment parameters and customs catalog
  • Implement a three-level technical document review process
• Risk transfer temporal nodes:
  • Under FOB terms, warranty period starts from port arrival inspection approval
  • CIF terms add clauses for technical parameter variations during transportation

New essential clauses for agency agreements

The 2025 standard agreement should pay special attention to three new elements:

• Dispute resolution mechanism:
  • Designate a list of third-party technical appraisal institutions
  • Establish graded compensation calculation standards
• Quality assurance linkage:
  • Clarify procedures for domestic and international warranty system integration
  • Specify customs declaration responsibilities for component replacements
• Special intellectual property provisions:
  • Pre-installed software copyright declaration clauses
  • Restrictions on domestic use of technical drawings

Key control points in operational processes

Process reengineering recommendations based on new regulatory requirements:

• Phased compliance review:
  • Complete pre-classification of equipment functions before signing contracts
  • Obtain electronic safety certification credentials before shipment
• Dynamic declaration mechanism:
  • Separate declaration of main equipment and intelligent components
  • Establish a fast track for subsequent tax supplements
• Archives management standards:
  • Extended retention period of technical documents to 5 years
  • Establish an electronic data hash evidence storage system

Warning analysis of typical cases

An imported medical device case showed three major losses due to untimely updates of classification standards:

• Incorrect classification resulted in a 9.8% deviation in tariff rates
• Lack of safety certification incurred port detention fees of 470,000 yuan
• Software copyright disputes led to subsequent legal disputes

By setting in the agency agreementTechnical parameter guarantee clausesandPre-certification service clauses, successfully transferred related risks to overseas suppliers.