Major Overhaul of China's Export Compliance: Challenges and Opportunities Under New Regulations Effective October 2025

Introduction

On October 1, 2025, China's export regulatory system will undergo a milestone transformation. With the formal implementation of Announcements No. 8 and No. 17, the era of long-standing "gray channel" customs clearance practices will come to an absolute close. Global supply chain companies are now confronted with unprecedented compliance challenges and transformation opportunities.

A New Regulatory Era: From Ambiguity to Transparency

The core of this reform lies in establishing a fully transparent and traceable export regulatory system. The new rules mandate that all export documents must clearly label the actual producer and seller entity, ensuring a direct link between the goods and the exporting entity. This change signifies:

·  The end of using third-party export licenses.

·  Supply chain transparency becomes a basic requirement.

·  Data authenticity becomes the cornerstone of compliance.

In-Depth Analysis of Key Policies

Upgraded VAT Management (Announcement No. 8)

The new regulations impose higher requirements for export rebate management: pre-export tax registration becomes mandatory, and companies must ensure complete consistency of information across the three stages of invoicing, customs declaration, and foreign exchange receipt. Any discrepancies will affect rebate processing timelines and may even lead to penalties.

Industry Impact and Response Strategies

E-commerce Faces Restructuring

The model reliant on logistics intermediaries for consolidated customs declarations is becoming unsustainable. E-commerce enterprises need to:

·  Establish compliant procurement and export channels.

·  Ensure matching between foreign exchange receipts and export declarations.

·  Improve supplier compliance management.

Manufacturers Urged to Transform

Production enterprises must move from behind the scenes to the forefront, building comprehensive export compliance systems, including:

·  Upgrading financial and customs management systems.

·  Establishing management processes ensuring consistency among goods, documents, and payments.

·  Carefully selecting compliant logistics partners.

International Procurement Strategy Adjustments

Overseas buyers should actively respond by:

·  Assisting Chinese suppliers in completing their compliance transition.

·  Considering establishing local entities in China.

·  Restructuring their procurement supply chain systems.

Tightened Controls on Dual-Use Items

In addition to general trade supervision, the management of dual-use item exports will also be significantly strengthened:

·  Implementation of a "one license, one use" system.

·  Expansion of the regulatory scope to include methods like postal and carry-on items.

·  Establishment of a fully digitalized management system.

Corporate Action Guide

With less than a year in the transition period, companies are advised to start immediately:

·  Conduct a comprehensive compliance gap analysis.

·  Restructure export business models and processes.

·  Invest in digital management systems.

·  Strengthen management of supply chain partners.

·  Establish ongoing compliance training mechanisms.

Conclusion

This reform represents not only an upgrade of China's export regulatory system but also a critical node in the restructuring of the global trade landscape. Companies that proactively adapt to the new regulations will discover new growth opportunities amidst the challenges. Compliance is no longer just a cost but a vital component of corporate core competitiveness.