How to sell in China without a Chinese company

What the rules allow

In most countries, selling to consumers means importing first. A local company brings the goods in, pays the taxes and takes legal responsibility for the product.

China offers a second way. Since 2019, a set of rules from six government departments has defined cross-border e-commerce retail import: a consumer in China buys from an overseas seller through an e-commerce platform, and the goods enter under one of two customs codes.

Under these rules:

• The seller is an overseas company. The rules name the seller as a company registered outside China and the owner of the goods.
• Customs treats the goods as personal-use articles. The licenses, registrations and filings that China requires the first time a product is imported do not apply. Two exceptions: goods China has suspended from import, and products under a safety alert.
• The tax is reduced. Inside the limits, the tariff is 0%, and import VAT and consumption tax are charged at 70% of the normal amount.

For product categories that need registration under general trade, the second point removes the slowest step.

The four things you need

1. A product on the list. China publishes a Cross-Border E-Commerce Retail Import Goods List. Your product’s HS code has to be on it.

2. A platform. The sale runs through a third-party platform registered in China. The platform sends each order record to customs.

3. An agent in China. You appoint one company registered in China. It registers with customs, declares your goods and shares civil liability with you.

4. A logistics route. Either you ship each order from abroad, or you hold stock in a bonded warehouse inside China.

Direct purchase or bonded stock

The two customs codes are two ways of running the same business.

Two modes of cross-border e-commerce import

	Direct purchase (code 9610)	Bonded import (code 1210)
Where stock sits	In your warehouse abroad	In a bonded warehouse inside China
How an order ships	From abroad, one parcel per order	By domestic courier from the bonded warehouse
When tax is due	When each parcel clears customs	When each order leaves the bonded warehouse
Cash tied up	Little. You ship what has sold.	Stock and bulk freight, paid before sales
Suits	Testing demand, wide ranges, slow sellers	Proven products with steady orders

The tax treatment is identical. Bonded stock is not taxed while it waits. If it does not sell, it can leave China again without ever being imported.

What the shopper pays

Each shopper has two limits: RMB 5,000 per order and RMB 26,000 per year. Inside them, the tariff is 0% and the shopper pays 70% of the normal import VAT and consumption tax. The tax is charged on the transaction price, with freight and insurance included. For a product with 13% VAT and no consumption tax, it comes to 9.1% of that amount.

A single item above RMB 5,000 can still be sold this way when it is the only item in the order and the shopper is inside the annual limit. It is taxed in full at the rates for ordinary cargo.

The shopper is the taxpayer. The platform, the logistics company or the declaring company collects the tax and pays it to customs for them.

What customs checks on every order

Three records reach customs before a parcel is released: the order from the platform or your agent, the payment from the payment company, and the waybill from the logistics company. Customs matches them. An order that does not match is not released.

Your agent, or a customs broker it appoints, then files a declaration list for the parcel. The platform or agent also has to verify the identity of the person ordering.

Most of this happens between systems, with no person involved. Your logistics partner’s system has to speak to customs, and so does your platform’s.

The limits of this route

• Online sales to consumers only. You cannot supply distributors or stores this way.
• No resale. Buyers purchase for their own use.
• Listed products only.
• You stay responsible for the product. The rules put primary responsibility for quality and safety on the overseas seller. You and the platform must show shoppers a risk notice before they order, and they have to accept it.

When a Chinese entity becomes worth it

Stay with cross-border e-commerce while your sales are online and your products are on the list. Consider general trade, with a Chinese importer or your own entity, when you want shelf space in physical stores, when distributors ask for stock, or when your best customers reach their annual limits.

Brands that reach that point know which products sell in China. The registration cost then buys access for products with proven demand.