International: China

At a glanceRequirements at a glance

International Freight Forwarding Enterprise Filing (MOFCOM)

Required where applicable. A company acting as an international freight forwarding agent (booking transport, coordinating carriage, arranging warehousing, without bearing carrier-level legal responsibility for the goods) must file as an International Freight Forwarding Enterprise with the Ministry of Commerce, or an MOFCOM-authorized local commerce department, under the Measures for the Filing of International Freight Forwarding Enterprises. This is the more foundational of the two registrations.

NVOCC Registration (Ministry of Transport)

Required where applicable. A company that issues its own bills of lading and assumes carrier-level liability for the ocean leg, rather than acting purely as an agent, registers as a Non-Vessel Operating Common Carrier (NVOCC) with the Ministry of Transport’s Water Transport Bureau. A 2019 reform replaced the earlier deposit requirement with registration. Some larger forwarders hold both the MOFCOM filing and NVOCC registration; smaller and mid-sized movers more typically hold only the MOFCOM filing.

Business Scope and Capital Requirements

The MOFCOM filing requires the registering entity to be a properly incorporated company (limited liability or joint-stock). Available sources commonly cite a minimum registered capital of RMB 5 million for maritime international freight forwarding, increasing by RMB 500,000 for each additional branch conducting this business. Carriers and entities with administrative monopoly functions may not apply. For NVOCC registration, the company’s registered business scope must include “无船承运业务” (NVOCC business).

Subcontracted Freight

Movers commonly contract the ocean or air leg to shipping lines, airlines and other forwarders. Where they do, those companies’ own registrations cover the services they perform.

OverviewOverview & Scope

For the international sea and air segment of a move, two separate government registrations are relevant. The International Freight Forwarding Enterprise filing with MOFCOM is the more foundational one. It covers a company acting as a coordinating agent (booking, arranging carriage, warehousing) without assuming carrier-level legal responsibility for the goods, and is the registration most directly relevant to a mover arranging, rather than itself carrying, the international leg. NVOCC registration with the Ministry of Transport is a separate, higher tier: a company holding it issues its own bills of lading and takes on carrier liability, similar in legal position to an actual carrier. A company can hold the MOFCOM filing alone, or both registrations together, depending on the role it takes for the international leg. Customs declarations are a separate matter covered in Country Guides.

RegistrationRegistration & Compliance Essentials

Movers must:

1. File as an International Freight Forwarding Enterprise with MOFCOM (or an authorized local commerce department) if arranging international sea or air freight as a forwarding agent, meeting the applicable registered capital requirement.
2. Register as an NVOCC with the Ministry of Transport’s Water Transport Bureau if issuing the company’s own bills of lading and assuming carrier-level liability for the ocean leg.
3. File freight rates with the Shanghai Shipping Exchange following NVOCC registration, where applicable.
4. Where the international leg is subcontracted, use shipping lines, airlines and forwarders that hold the registrations required for the services they perform.

ChecklistCompliance checklist

Company licensing

• International Freight Forwarding Enterprise filing held with MOFCOMWhere applicable (mover arranges international sea or air freight as a forwarding agent)Verified by DocumentRequired
• NVOCC registration held with the Ministry of TransportWhere applicable (mover issues its own bills of lading or assumes carrier liability for the ocean leg)Verified by DocumentRequired
• Freight rates filed with the Shanghai Shipping ExchangeWhere applicable (mover holds NVOCC registration)Verified by DocumentRequired

Subcontracted transport

• Where transport is subcontracted, the mover uses carriers that hold the licences required for the transport they performWhere applicableVerified by AffirmationRequired