General Administration of Customs: An Interpretation of the Registration and Filing Enterprise Credit Management Measures of the General Administration of Customs of the People's Republic of China 

 

 

In implementation of the national strategies to improve the social credit system and refine the credit restoration mechanism, and to further optimize the Customs credit management regime, the General Administration of Customs promulgated the Registration and Filing Enterprise Credit Management Measures of the General Administration of Customs of the People's Republic of China (Order No. 282 of the General Administration of Customs of the People's Republic of China) on January 13, 2026. The Regulations shall enter into effect on April 1, 2026. To facilitate a comprehensive understanding and accurate grasp of the regulatory amendments among concerned entities and the public, key aspects are interpreted as follows.

I. Background and Rationale for the Amendments

The Registration and Filing Enterprise Credit Management Measures of the General Administration of Customs of the People's Republic of China (Order No. 251 of the General Administration of Customs), enacted on November 1, 2021, have played a significant role in standardizing Customs administration of enterprises and supporting the development of China’s national social credit system.However, subsequent developments have necessitated these amendments. These include the continued advancement of the national social credit system, the accelerated expansion of international mutual recognition under the Authorized Economic Operator (AEO) framework, and the imperative to modernize Customs’ enterprise credit management practices. Consequently, specific aspects of the current regulatory framework require refinement, particularly provisions concerning enterprise credit classification, AEO certification procedures, differentiated management measures, and mechanisms for the restoration of credit standing following instances of non-compliance.

II. Key Amendments

(I) Refined Classification of Enterprise Credit Tiers

To implement the national social credit system and align with international norms, the enterprise credit classification has been restructured from three tiers into five: Advanced Certified Enterprise, Certified Enterprise, General-Compliance Enterprise, Discredited Enterprise, and Seriously Discredited Enterprise (Article 4). The Regulations formally designate Advanced Certified Enterprises and Certified Enterprises as China’s Authorized Economic Operators (AEOs) (Article 8).

(II) More Flexible Enterprise Credit Management by Tier

Based on an enterprise’s credit standing, Customs will apply differentiated management measures corresponding to each of the five credit tiers (Paragraph (1) under Article 32). The specific measures for each tier shall be formulated and issued separately by the General Administration of Customs (Paragraph (2) under Article 32).

(III) Establishing a Credit Restoration Mechanism for Non-Compliant Enterprises

A dedicated chapter (Chapter V) has been introduced, focusing on the disclosure and restoration of enterprise non-compliance records. This chapter establishes uniform channels for such disclosure and designates the national "Credit China" website as the official platform for Customs to publish these non-compliant records (Article 33). The classification standards for non-compliance records have been upgraded, now categorizing such records into three tiers: minor, general, and serious, each subject to a distinct disclosure period (Articles 34 and 35). In operational terms, to align the regulations with the practical realities of credit management for Customs-registered/filed enterprises, the regulations formally integrate relevant provisions of the national social credit system governing the restoration process. These cover application conditions and supporting documents, processing timelines, restoration outcomes, procedures for filing objections, and circumstances where restoration is not permitted (Articles 36 to 40). Additionally, the Regulations streamline the criteria for an enterprise currently designated as non-compliant to apply for an upgrade in its credit tier (Articles 29 and 30).

(IV) Refining the Identification Criteria for Discredited Enterprises and Seriously Discredited Enterprises

The identification criteria for Discredited Enterprises have been refined. The revised criteria draw a clearer distinction between the circumstances under which enterprises engaged in both Customs declaration and non-declaration activities may be designated as discredited. Furthermore, to strengthen export controls, the criteria for designation as a Discredited Enterprise now expressly include the intentional violation of export control laws that result in Customs-imposed administrative penalties (Article 15). In line with thedevelopment objectives of national social credit system, the criteria for identifying Seriously Discredited Enterprises have been upgraded. The Regulations provide that any enterprise classified as Seriously Discredited by Customs authority will simultaneously be entered on the List of Seriously Discredited Entities under Customs Import-Export Supervision (Article 16).

(V) Streamlined Certification Procedures for Advanced Certified Enterprises and Certified Enterprises

Article 19 sets forth new eligibility criteria for personnel who conduct AEO certifications. Article 20 allows for the suspension of the certification timeline during Customs audits, verification or investigations.The Regulations maintain the requirement for Advanced Certified Enterprises to undergo re-certification every five years. For Certified Enterprises, re-certification will be triggered by their periodic credit assessment results. According to Articles 22 and 23, a new, simplified re-certification procedure has also been established.

(VI) Refinements to the Credit Management Framework in Response to Operational Needs

Article 11 establishes an obligation for enterprises to file annual credit information reports. Article 41 extends the scope of these Regulations to also cover enterprises that are not registered or recorded with Customs but are directly engaged in import-export operations. Such enterprises may be placed under credit management in accordance with these rules. Article 46 broadens the definition of “enterprise-related personnel” to include Customs declarants, whose information may be collected for credit assessment purposes.

(Prepared by: Department of Policy and Legal Affairs, Department of Enterprise Management and Audit-Based Control)