The Compliance Lifeline of Agency Service Fee Invoices

After the implementation of General Administration of Customs Announcement No. 22 of 2025, a medicalEquipment Importscompany experienced 28 days of customs clearance delays due to incorrect classification of agency fee invoices, resulting in demurrage fees and breach penalties totaling 1.27 million yuan. This real case reveals:Agency service fee invoice processing directly impacts equipment import costs and timelines.

Key Points for Invoice Type Identification

Three critical invoice types involved in import processes:

• Proforma Invoice
  • Used for advance payment applications
  • Must be marked with Not Final Settlement,
• Commercial Invoice
  • Must match the customs declaration amount
  • Must distinguish between equipment costs and service fees
• Split Invoice
  • Applicable for installment payment projects
  • Must maintain original contract number continuity

2025 New Fee Processing Regulations

According to the latest customs valuation methods:

• Agency fee proportion warning lineIncreased to 12% of total contract value
• Technical service fees requireTimesheet recordsFor reference
• Logistics surcharges must be listed separately

Analysis of typical risk scenarios

• Hidden fee traps
  • A German equipment import contract failed to specify document processing fees,
  • Resulting in additional VAT payment of 87,000 CNY during customs clearance
• Exchange rate fluctuation blind spots
  • A Japanese company failed to include currency locking clauses in invoices
  • Exchange rate differences led to overpayment of 230,000 CNY in agency fees

Professional invoice review checklist

Recommend enterprises establish a three-tier verification mechanism:

• Basic element verification
  • Completeness of buyer/seller information
  • Consistency between HS codes and customs declaration
• Fee breakdown validation
  • Separate listing of equipment costs and service fees
  • Clear identification of royalty fees
• Policy compliance review
  • Method of origin standard labeling
  • Anti-dumping duty warning indicators

Risk prevention operation recommendations

• Add to agency agreementsInvoice dispute resolution clauses
• Require agents to provideDocuments supporting customs advance rulings
• EstablishElectronic invoice comparison systemAutomatic verification

An auto parts importer successfully avoided 3 customs valuation inquiries in the first half of 2025 by improving invoice management processes, saving 15 working days in clearance time. Data shows standardized agency fee invoices can reduce total import costs by 4.7%. Enterprises are advised to refer to the General Administration of Customs Guide to Price Declaration for Imported Goods (2025 revised edition) and update internal review standards quarterly.