I. The Legal Positioning Trap of the Power of Attorney Certificate

Under the framework of the newly revised "Administrative Measures for the Import of Electromechanical Products" in 2025, a legally valid agency authorization certificate must includeTripartite Rights and Responsibilities Clause。During our handling of a case involving the import of German machine tools, we discovered:

• The manufacturer has not explicitly indicated the permission for sublicensing.
• The general agent did not restrict the sales territory of the sub-agent.
• The authorization document lacks the anti-counterfeiting label required by the General Administration of Customs.

II. Compliance Boundaries of Core Elements in Certificates

According to the data from the Ministry of Commerce's 2025 Import Equipment Agency Filing System, 32% of authorization disputes stem from ambiguous clause wording. A valid certificate must include:

• Authorization time dimension
  • The effective date is invalid if it is earlier than 90 days before the customs declaration date.
  • The validity period must cover the equipment warranty cycle.
• Authorization scope limitation
  • The product serial number range is accurate down to individual batches.
  • The terms of service should distinguish between installation and commissioning and after-sales maintenance.

III. Verification Blind Spots in Cross-Border Authorization Chains

Our agency's case studies on Japanese precision instruments indicate that complete authorization documents should include:

• Original factory notarized and certified documents
  • The document requires three levels of authentication by Chinese embassies or consulates abroad.
  • The translation document must bear the seam-sealing stamp of a professional translation company.
• Legal equivalence of electronic signatures
  • Differences between the EU eIDAS Regulation and the US ESIGN Act
  • Judicial Admissibility Standards for Blockchain-Based Evidence Preservation Technology

IV. Policy Outlook and Response Strategies for 2025

Regarding the upcoming new regulations on cross-border authorization filing, it is recommended that enterprises:

• Establish a dual-track verification mechanism for authorization documents.
  • Cross-verification between paper documents and electronic filing systems
  • Dynamically update the customs HS code correspondence table
• Improve risk hedging clauses
  • Specify the exchange rate fluctuation sharing mechanism in the authorization agreement.
  • Establish the obligation of prior notice for changes in technical parameters.

V. Risk Prevention and Control in Practical Cases

A certain medical?Equipment import?In the project, we achieved throughFour - step verification methodAvoid losses:

• Check whether the authorization chain is broken.
  • Manufacturer → Greater China General Agent → Provincial Agent's complete chain
• Verify the hierarchy of seal validity.
  • The consistency between the original factory seal and the registered seal in China.
• Confirm the corresponding customs declaration elements.
  • Accurate Matching of Equipment Models and Authorization Scope
• Preserve legal remedies.
  • Agreement on Dispute Resolution Venue and Applicable Law Terms