Insights into the Core Changes of 2025 Agency Terms

In accordance with Announcement No. 48 of the General Administration of Customs, the agency business for imported equipment will undergo three major adjustments:

• Customs Classification Rules Iteration:
  • Composite function equipment adopts the principle of primary function priority.
  • The intelligent module component must be declared for its value separately.
• Security Certification Pre-Processing Procedure:
  • Class IIMedical EquipmentMandatory implementation of pre-shipment compliance verification
  • The certification scope for industrial equipment safety protection levels has been expanded to 13 categories.
• Redefining the Boundaries of Agency Responsibility:
  • The accountability period for reporting errors is extended to 36 months after the release of goods.
  • Quality disputes introduce a "technical feasibility" exemption clause.

Key Points for Building a Risk Prevention System

It is recommended to establish a triple protection mechanism in the agency agreement:

• Pre-classification Dispute Resolution Plan:
  • Request the supplier to provide a functional module breakdown description.
  • It is recommended to reserve a 5% tariff deposit.
• Technical Compliance Review Closed Loop:
  • Establish a mapping database between equipment parameters and customs catalogues
  • Establish a three-level review process for technical documents.
• Time-space node of risk transfer:
  • Under FOB terms, the warranty period starts from the date of passing the port inspection.
  • Add a clause on technical parameter variations during transit under CIF terms.

Additional Mandatory Clauses for the Agency Agreement

The 2025 version of the standard agreement should pay special attention to three newly added elements:

• Dispute Resolution Mechanism:
  • List of Agreed Third-Party Technical Appraisal Institutions
  • Set the graded compensation calculation criteria
• Quality Assurance Handover:
  • Clarify the interface procedures between domestic and international quality assurance systems
  • Specify the customs declaration responsible party for component replacement
• Special Agreement on Intellectual Property:
  • Copyright Notice for Pre-installed Software
  • Restrictions on Domestic Use of Technical Drawings

Key Control Points in the Operational Process

Process Reengineering Recommendations Based on New Regulatory Requirements:

• Phased Compliance Review:
  • Complete equipment function pre-classification before signing the contract.
  • Obtain the electronic safety certification credential before shipment.
• Dynamic Reporting Mechanism:
  • Spin-off declaration of main equipment and intelligent components
  • Establish a fast-track channel for subsequent tax supplements.
• Archives Management Standards:
  • The retention period for technical documents has been extended to 5 years.
  • Establish an electronic data hash-based evidence preservation system.

Typical Case Warning Analysis

A case of medical device imports demonstrates that failure to promptly update classification standards resulted in three major losses:

• Misclassification resulted in a 9.8% deviation in tariff rates.
• The lack of safety certification resulted in port detention fees of 470,000 yuan.
• Disputes over software copyright have led to subsequent legal conflicts.

By setting in the proxy protocolTechnical Parameter Warranty ClauseandPre-certification Service Terms, successfully transferring the relevant risks to overseas suppliers.