Q: Do I need a separate “import-export license” document?

A: China no longer issues a physical “import-export license” document. The term “import-export license” (进出口许可证) colloquially refers to the completed registration process. The legal basis for importing and exporting is the company’s customs registration record (海关备案回执, hǎiguān bèi’àn huízhí), which is a digital record in the Customs database. When you complete customs registration through the Single Window, Hefei Customs issues an electronic confirmation that your company is recorded as an “importer and exporter of goods” (进出口货物收发货人). This electronic record, combined with your Customs Registration Code (10-digit海关编码), constitutes your legal authority to import and export. You do not need to display or hold a physical paper license. The customs code is embedded in your Electronic Port IC card (电子口岸IC卡), which you present (or authenticate digitally) during each customs declaration.

Q: Can a foreigner be the legal representative of an Anhui company that exports?

A: Yes, a foreign national can serve as the legal representative (法定代表人, fǎdìng dàibiǎo rén) of an Anhui-based company that imports and exports. The legal representative must: (1) Hold a valid work visa (Z-visa) and work permit (外国人工作许可证, wàiguórén gōngzuò xǔkězhèng). (2) Hold a valid residence permit for the duration of their role. (3) Provide a passport and notarized proof of identity. The foreign legal representative can sign off on customs registration applications, SAFE registration, and bank account openings. In practice, many FIEs in Anhui appoint a Chinese national (often the general manager or a local staff member) as the customs declarant (报关员, bàoguān yuán) — the person named on the Electronic Port IC card who is authorized to submit customs declarations electronically — while the foreign legal representative retains overall legal authority. This is common because the declarant must be physically present or digitally authenticated in China (via the IC card or mobile authentication), and having a local staff member in this role streamlines day-to-day operations.

Q: How does the Anhui International Trade Single Window work?

A: The Anhui International Trade Single Window (安徽国际贸易单一窗口) is the unified online portal for all import-export related government procedures. Available at www.singlewindow.ah.cn, it allows companies to: (1) Submit customs registration applications and track processing status. (2) Submit electronic customs declarations (报关单, bàoguān dān) — the primary function for daily operations. (3) Apply for certificates of origin (原产地证书, yuánchǎndì zhèngshū). (4) Submit tax refund applications to the tax bureau. (5) Manage Electronic Port digital certificates. (6) Access trade policy updates and tariff rate information. The system operates 24/7, and customs declarations submitted before 4:00 PM on working days are typically processed the same day. The Single Window uses digital certificates (loaded on the IC card or USB key) for authentication and digital signatures. To access the system, you need to: install the Electronic Port client software; obtain your IC card or USB digital certificate (from Hefei Electronic Port Data Center); register an administrative account. The system supports Chinese and English interfaces, though customs declarations must be filled in Chinese with supplementary English descriptions.

Q: What is a “customs registration code” and how do I get one?

A: The Customs Registration Code (海关编码, hǎiguān biānmǎ), also called the “Customs Registration Number of Importers and Exporters” (进出口货物收发货人海关注册编码), is a 10-digit alphanumeric code that uniquely identifies your company for all customs and trade procedures in China. The code structure is: Digits 1-4: Administrative region code (3401 for Hefei City, Anhui Province; 3400 for Anhui Province general). Digits 5-7: Company registration serial number. Digit 8: Enterprise type indicator (e.g., W for WFOE, B for domestic general enterprise, C for processing trade enterprise). Digits 9-10: Check digits/verification. You obtain this code by completing Step 2 (Customs Registration) in the process above. Once Hefei Customs approves your registration, the code is automatically generated and displayed in your customs registration confirmation (海关备案回执). This code must be included on all customs declarations, invoices, bills of lading, and export documents. It is also linked to your Electronic Port IC card. There is no fee to obtain the code itself, and it remains valid as long as your company maintains its registration status.

Q: Can I export before my import-export registration is fully complete?

A: No, you cannot legally export goods before completing customs registration and obtaining your Customs Registration Code. Unregistered export is considered smuggling (走私, zǒusī) under Chinese Customs Law and can result in: (1) Seizure of goods. (2) Fines of 10-100% of the value of the goods involved. (3) Customs registration blacklisting. (4) Potential criminal penalties for serial violations. However, there are two legal workarounds while registration is in process: (1) Use a licensed export agent (外贸代理, wàimào dàilǐ) in Hefei — the agent uses its own customs registration to declare and export your goods on your behalf. This is perfectly legal and common for first-time exporters. Agent fees typically range from 1-3% of FOB value. (2) Use a cross-border e-commerce platform (e.g., Alibaba.com, Made-in-China.com) that handles customs clearance for small-value shipments under the cross-border e-commerce retail export (跨境电商零售出口, kuàijìng diànshāng língshòu chūkǒu) channel, which has streamlined customs procedures. Neither approach requires your company to have its own customs registration, though using an agent is recommended for B2B export shipments of any significant value.

Q: What happens if I don’t complete the export tax refund registration?

A: Export tax refund registration is mandatory, not optional, for any company that exports goods from China. If you export without completing tax refund registration: (1) You will not be able to claim VAT refunds (出口退税) on exported goods, losing 9-13% of your input VAT that would otherwise be recoverable. (2) The Hefei Tax Bureau may demand that you pay VAT on exported goods as if they were domestic sales (i.e., at 13% on the export value). (3) Your customs registration may be suspended for non-compliance with tax authority requirements. (4) Penalty fines may apply for failure to register within 30 days of your first export customs declaration. The tax refund registration does not need to be completed before first export — you have 30 days from your first customs declaration to submit the registration. However, to avoid complications, it is strongly recommended to complete it before or simultaneously with customs registration. The tax refund registration has no direct cost and can be filed online through the Single Window system. Once registered, you must file export tax refund applications quarterly (for most enterprises) or monthly (for AEO-certified enterprises) to recover the VAT.

Q: Do I need a special license to import specific types of goods?

A: Yes, certain categories of goods require additional licensing beyond the standard customs registration. If your Anhui company plans to import goods in any of the following categories, you need supplementary licenses: (1) Food and food additives — Registration with the Hefei Entry-Exit Inspection and Quarantine Bureau (now part of Customs), plus filing with the Anhui Food and Drug Administration for certain categories. Overseas food manufacturers must also be registered with China’s General Administration of Customs (GAC) under Decree 248/249. (2) Medical devices and pharmaceuticals — Import Drug License (进口药品注册证, jìnkǒu yàopǐn zhùcè zhèng) from the National Medical Products Administration (NMPA), plus Good Supply Practice (GSP) certification. (3) Chemical products, especially hazardous chemicals — Hazardous Chemicals Operating License (危险化学品经营许可证, wēixiǎn huàxué pǐn jīngyíng xǔkězhèng) from the Anhui Department of Emergency Management. (4) Cosmetics — NMPA registration for imported cosmetics. (5) Dual-use items and technologies — Import license from the Ministry of Commerce for items that could have military applications. (6) Waste and scrap — Import license from the Ministry of Ecology and Environment (highly restricted since China’s ban on solid waste imports). For standard manufactured goods (electronics, machinery, auto parts, textiles, furniture), no special import license is required beyond the standard customs registration.

Q: How long is the import-export registration valid, and do I need to renew it?

A: Customs registration (海关备案) in China has no fixed expiration date — it remains valid for the duration of the company’s existence, provided that: (1) The company files annual customs registration updates confirming that basic information (address, legal representative, business scope) remains unchanged. (2) The company has conducted at least one import or export transaction within the past two years — otherwise, the registration may be marked as “inactive” (休眠, xiūmián). (3) The company’s business license remains valid and in good standing with the market supervision authority. (4) The Electronic Port IC cards/digital certificates must be renewed every 2-3 years (cost: approximately RMB 350 per card). (5) If the company changes address, legal representative, or business scope, the customs registration must be updated within 30 days of the change. Failure to update may result in customs registration suspension and the inability to clear shipments. The annual update process is a simple online confirmation through the Single Window system and takes approximately 1-2 hours of administrative time.

Q: Can I outsource the entire import-export registration process?

A: Yes, you can engage a professional service provider to handle the entire registration process. Options include: (1) Licensed customs brokers (报关行, bàoguān háng) — These are certified customs clearance service companies that can handle registration as part of a broader service package. Major brokers in Hefei include Sinotrans Anhui (中国外运安徽), Hefei Customs Brokerage Service Co., and international firms such as Kuehne+Nagel and DHL Global Forwarding. (2) Company registration agents — Many Hefei-based company setup agencies (企业注册代理, qǐyè zhùcè dàilǐ) offer end-to-end “trade-ready” packages that include business license establishment, customs registration, tax registration, and bank account opening. These agencies charge RMB 5,000-15,000 depending on the scope of services. (3) Law firms specializing in trade law — Law firms with customs and trade practice groups can handle the legal aspects, particularly for FIEs with complex corporate structures. Hourly rates for trade lawyers in Hefei range from RMB 800-2,000 per hour. (4) One-stop service centers in development zones — Many industrial parks and development zones in Anhui (e.g., Hefei Economic and Technological Development Zone, Hefei High-Tech Zone) operate one-stop service centers (一站式服务中心, yīzhànshì fúwù zhōngxīn) that provide free assistance with import-export registration for companies located within the zone. This is often the most cost-effective option for companies already established in these zones.

Q: What is the difference between customs registration for a WFOE vs. a Representative Office?

A: There is a fundamental difference in import-export capabilities between the two entity types: (1) Wholly Foreign-Owned Enterprise (WFOE, 外商独资企业, wàishāng dúzī qǐyè): A WFOE registered in Anhui with “import and export” in its business scope can conduct direct import-export operations using its own customs registration. It can sign contracts with overseas buyers, issue invoices, receive foreign currency payments, and claim VAT refunds. A WFOE is the appropriate entity type for any foreign company planning to manufacture or trade goods from Anhui. (2) Representative Office (代表处, dàibiǎo chù): A Representative Office in China is NOT permitted to engage in direct profit-making activities, including import-export. A Representative Office cannot register with Hefei Customs under its own name or obtain a customs registration code. It cannot sign import-export contracts or receive foreign currency payments for trade transactions. The Representative Office can conduct market research, liaison, and quality inspection, but all import-export activities must be routed through either: (a) a WFOE subsidiary with customs registration; (b) a licensed trading company/agent; or (c) the foreign parent company directly (CIF/FOB basis with the Chinese supplier). Foreign companies serious about Anhui manufacturing or sourcing should establish a WFOE rather than a Representative Office.

Q: What other registrations do I need if I’m processing imported materials for re-export?

A: If your Anhui-based company plans to import raw materials or components duty-free, process them into finished goods, and re-export the finished goods, you need additional registrations beyond the standard import-export license: (1) Processing Trade Registration (加工贸易备案, jiāgōng màoyì bèi’àn) — Register with Hefei Customs for a “Processing Trade Handbook” (加工贸易手册, jiāgōng màoyì shǒucè) that tracks the import of bonded materials, their processing, and export of finished goods. This registration is required to qualify for duty-free import of raw materials used in export production. (2) Bonded Warehouse Registration (保税仓库备案, bǎoshuì cāngkù bèi’àn) — If you plan to store imported materials in a bonded facility, the warehouse itself must be registered with customs. Companies within the Anhui Pilot Free Trade Zone (Hefei Area) have simplified procedures for this. (3) Customs supervisory area registration — If your processing factory is outside an FTZ or comprehensive bonded zone, your production facility may need to be registered as a “supervised processing area” (海关监管加工区, hǎiguān jiānguǎn jiāgōng qū). (4) ERP system integration — For high-volume processing trade operations, Hefei Customs may require your company’s ERP system to be integrated with the Customs surveillance system for real-time tracking of bonded materials. These additional registrations extend the total setup timeline by 2-4 weeks and may require investment in customs-compliant ERP software. Companies within the Anhui FTZ benefit from simplified processing trade procedures under the “zone-based” (区内, qū nèi) regime.

Q: Where do I physically go to submit documents in Hefei?

A: While most processes are now online through the Anhui International Trade Single Window, certain steps require physical presence or document submission at specific Hefei addresses:

• Hefei Customs (合肥海关) — Main office: No. 88 Qingxi Road, Shushan District, Hefei (合肥市蜀山区清溪路88号). Customs registration inquiries: General Affairs Hall, Ground Floor. Phone: 0551-12360 (customs service hotline).
• Hefei Electronic Port Data Center (合肥电子口岸数据分中心) — EDI card application and renewal. Adjacent to Hefei Customs at the same address.
• SAFE Anhui Branch (国家外汇管理局安徽省分局) — No. 20 Chengqu Road, Luyang District, Hefei (合肥市庐阳区城区路20号, within Hefei Central Sub-branch of the People’s Bank of China).
• Hefei Tax Bureau, Export Tax Refund Division (合肥市税务局出口退税科) — No. 15 Lujiang Road, Luyang District, Hefei (合肥市庐阳区庐江路15号).
• Anhui Market Supervision Bureau (安徽省市场监督管理局) — Provincial Hall for business license amendments: No. 238 Xiangzhang Avenue, Baohe District, Hefei (合肥市包河区香樟大道238号).
• Hefei High-Tech Zone One-Stop Service Center (合肥高新区一站式服务中心) — For companies in the Hefei High-Tech Zone: free registration assistance available at the zone’s service hall.

Office hours for all government offices: Monday to Friday, 9:00 AM to 12:00 PM and 1:30 PM to 5:00 PM. Many offices now accept walk-in appointments, though online appointment booking is recommended.

Q: Can I register for import-export if my company is in a Special Economic Zone in Anhui?

A: Yes, companies located in Anhui’s special economic zones — including the Hefei Area of the Anhui Pilot Free Trade Zone (安徽自贸试验区合肥片区), the Hefei Economic and Technological Development Zone (合肥经济技术开发区), the Hefei High-Tech Industrial Development Zone (合肥高新技术产业开发区), and the Wuhu Comprehensive Bonded Zone (芜湖综合保税区) — benefit from streamlined registration procedures. Specifically: (1) Simplified customs registration — Companies in FTZ and bonded zones can often complete customs registration within 24 hours (vs. 1-3 working days standard). (2) Combined registration form — Some zones accept a single application that covers customs registration, inspection registration, and electronic port certification simultaneously. (3) On-site service centers — Most zones have dedicated customs liaison officers who assist with the registration process. (4) “Green channel” for qualified enterprises — Zone-based companies with good compliance records may qualify for priority processing. (5) AEO certification fast-track — Companies in FTZ areas may qualify for a 30-day fast-track AEO certification process (vs. 3-6 months standard). Foreign-invested enterprises are particularly encouraged to locate in these zones, as the streamlined procedures significantly reduce the time and cost of becoming trade-ready.

Q: How do I update my import-export registration if I change my company address in Anhui?

A: Updating your import-export registration following a change of address within Anhui Province involves: (1) First update your business license with the Anhui Market Supervision Bureau (5-10 working days). (2) Then update your customs registration through the Single Window system — select “Registration Change” (注册信息变更, zhùcè xìnxī biàngèng) and submit the new address with supporting documentation. Hefei Customs processes address changes within 1-3 working days. (3) Update your Electronic Port IC card information at the Hefei Electronic Port Data Center. (4) If the new address is in a different customs district (e.g., moving from Hefei to Wuhu), you must cancel your Hefei customs registration and re-register with Wuhu Customs. (5) Update your tax refund registration with the new district tax bureau. (6) Update your SAFE registration and bank account information if moving to a different city. There is no charge for registration updates processed through the Single Window. It is critical to complete these updates before conducting any new export shipments from the new address, as customs declarations with an outdated address can be rejected or subject to additional inspection.

Q: Is there a minimum registered capital requirement to get an import-export license in Anhui?

A: For most manufacturing and trading companies in Anhui, there is no minimum registered capital requirement specifically for import-export activities. China eliminated the minimum registered capital requirements for most company types in 2014 under the registered capital subscription system (注册资本认缴制, zhùcè zīběn rènjiǎo zhì). However, there are practical considerations: (1) The customs authorities expect that the company has sufficient working capital to support its declared trade volume. While there is no published minimum, companies with very low registered capital (e.g., RMB 50,000) exporting high-value goods (e.g., RMB 10 million shipments) may face additional scrutiny from Hefei Customs regarding the company’s financial capacity to fulfill trade obligations. (2) For FIEs, the actual contributed capital (实缴资本, shíjiǎo zīběn) may be reviewed during SAFE registration. Most banks require minimum contributed capital of RMB 100,000-300,000 to open a full-service foreign exchange settlement account. (3) Processing trade operations require a financial capability assessment — companies must demonstrate sufficient funds to pay duties and taxes if goods are diverted to domestic sale. (4) For cross-border e-commerce export licenses, platforms may impose their own minimums (typically RMB 100,000-500,000 registered capital). As a practical guideline, most successful first-time Anhui exporters have registered capital in the range of RMB 500,000-3,000,000, though this is driven by business needs rather than regulatory requirements.