Can a foreign company act as its own Importer of Record in China?

No. Only a company registered in China with a valid MOFCOM import/export license can act as Importer of Record. Foreign companies must use a licensed IOR service.

What is the difference between an IOR and a customs broker?

The IOR is the legal entity responsible for the import declaration. A customs broker is the agent that prepares and files the declaration. An IOR may work with a broker, or the IOR service may include in-house customs brokerage.

How are import duties calculated in China?

Import duties are calculated on the CIF value (cost, insurance, and freight) of the goods at the applicable tariff rate. Import VAT is then applied to the CIF value plus duty. An IOR handles this calculation and payment.

What happens if my goods require a license I don't have?

Without the required license, customs will hold the shipment. A qualified IOR verifies license requirements before shipment departure and obtains the necessary permits in advance.

Importer of Record (IOR) in China: Complete Guide to Import Agency Services

Importing goods into China requires a registered Chinese entity with import rights to appear on the customs declaration as the Importer of Record (IOR). For foreign companies without a subsidiary in China, this creates a fundamental challenge: you cannot legally import into your own name.

An Importer of Record service — also called import agency — solves this by providing a licensed Chinese entity to handle customs clearance, duty payment, and regulatory compliance on your behalf.

What Is an Importer of Record?

The Importer of Record is the entity that:

Appears on the import customs declaration as the consignee
Bears legal liability for the accuracy and completeness of the declaration
Is responsible for paying all applicable import duties and VAT
Holds any required import licenses or permits for controlled goods

In China, only a company with a valid MOFCOM import/export license can act as an Importer of Record.

When Do You Need an IOR in China?

Common scenarios include:

Foreign companies selling products into the Chinese market without a local entity
Overseas manufacturers shipping components or raw materials to their Chinese contract manufacturers
E-commerce businesses entering China's cross-border import channels
Companies participating in trade shows or sending demonstration equipment into China temporarily

What an IOR Service Includes

A comprehensive Importer of Record service covers:

Import customs clearance — Full declaration preparation and filing at the port of entry
Duty and tax payment — Assessment and payment of import duties and import VAT on your behalf
License and permit handling — Obtaining required import licenses (e.g., CCC certification waivers, food registration, chemical permits)
Foreign payment processing — Settling payment to the overseas supplier through China's foreign exchange system
Door-to-door delivery — Coordinating inland transportation from the port to your customer or warehouse in China

Import Duties and Taxes

When importing into China, the following duties and taxes apply:

Customs duty — Varies by HS code. Most-favoured-nation (MFN) rates range from 0% to 25%, with the average around 7.5%. Preferential rates may apply under free trade agreements.
Import VAT — Standard rate is 13%, reduced rate of 9% applies to certain goods (books, food staples, agricultural inputs).
Consumption tax — Applies to luxury goods, tobacco, alcohol, and certain automotive products. Rates vary by product category.

Total tax burden is calculated as: Duty + (CIF value + Duty) × VAT rate. An IOR handles this calculation and payment as part of the clearance process.

IOR for Cross-Border E-Commerce

With the growth of cross-border e-commerce into China, IOR services have expanded to support B2C import channels. Under the cross-border e-commerce retail import pilot program, certain goods can be imported with reduced duty rates and simplified clearance procedures. An IOR experienced in e-commerce operations can manage the bonded warehouse clearance process, handle individual order declarations, and coordinate with delivery partners for final-mile distribution. This model is particularly relevant for foreign consumer brands entering the Chinese market through Tmall Global, JD Worldwide, or their own direct-to-consumer cross-border platforms.

Consignment Stock and Bonded Warehouse

Foreign companies that maintain consignment stock in China face a distinct challenge: the goods need to be physically present in China before a domestic buyer is identified, but customs duty is only payable when goods are withdrawn from the bonded warehouse for domestic consumption. Under a bonded warehouse arrangement, the IOR clears the goods into a customs-supervised bonded warehouse without paying duty or VAT at the time of import. When a Chinese buyer is found and the goods are sold domestically, the IOR files a separate import declaration for each withdrawal and pays the duty and VAT on the quantity withdrawn. This model is widely used by foreign manufacturers that need to maintain local inventory in China without pre-paying duties on stock that may later be re-exported if not sold domestically.

Temporary Imports and Re-Export

For goods entering China temporarily — such as exhibition equipment, samples, or testing equipment — the IOR can manage the temporary import bond process. Under this arrangement, the IOR posts a customs bond equal to the duty and tax amount, and the bond is released when the goods are re-exported within the specified time limit (typically 6–12 months). This avoids paying duty and VAT on goods that will leave China without being consumed domestically. The IOR manages the bond documentation, tracks the re-export deadline, and ensures the bond is discharged on time to avoid penalties.

Regulated and Restricted Goods

Certain categories of goods require additional permits or licenses for import into China:

Food and agricultural products — Must be registered with GACC. Some categories require overseas manufacturer registration under the latest GACC Decree 280.
Cosmetics and personal care — NMPA registration required for many product types
Medical devices — NMPA registration and in some cases CCC certification
Chemicals — May require environmental and safety permits depending on the specific substance
Used and second-hand goods — Subject to strict inspection requirements and catalogue restrictions

A qualified IOR will verify these requirements before the shipment departs, preventing costly delays at the port of entry.

Partnering with a Licensed IOR

Choosing the right import agent matters because the IOR's compliance record directly affects your shipment's clearance probability. An IOR with AEO certification, a clean customs history, and dedicated port desks will consistently achieve faster clearance times than a generalist forwarder offering IOR as an add-on service.

Our import team manages each engagement with a dedicated case manager who coordinates with our customs desk at the arrival port, ensuring clearance is initiated before the vessel arrives and cargo is released within hours of docking for qualifying shipments.