
China's Market Procurement Trade Policy (Policy 1039) was designed to solve the invoice-free procurement challenges faced by cross-border e-commerce sellers. While promising in theory, many merchants report significant implementation hurdles that make the policy difficult to utilize effectively.
Policy 1039: A Solution That Falls Short in Practice?
The policy aims to simplify export procedures for small-scale cross-border transactions by allowing market purchases without value-added tax invoices. However, operational complexities have created barriers that prevent many businesses from benefiting.
Challenge 1: Business Registration and Filing Process
The initial requirement to register as an individual business operator and complete Policy 1039 filing appears straightforward but contains hidden complexities:
- Requirements vary significantly across different pilot zones
- Multiple platforms must be coordinated (procurement information systems, customs clearance systems, logistics)
- Service providers often lack comprehensive knowledge of the entire process
Solution: Partner with experienced service providers who understand both the policy and local implementation details across different regions.
Challenge 2: Logistics Provider Cooperation
Finding logistics partners capable of handling Policy 1039 procedures proves exceptionally difficult:
- Many freight forwarders have limited understanding of the policy
- Inefficient routing decisions create unnecessary costs and delays
- The industry lacks professionals with practical Policy 1039 experience
Solution: Select logistics providers with proven Policy 1039 experience and verify their understanding before engagement.
Challenge 3: Export Authorization Activation
The required entrustment agreement for export authorization presents additional obstacles:
- Activation through the Single Window system requires specific qualifications
- Newly established companies often lack necessary credentials
- Alternative activation channels increase time and cost burdens
Solution: Work with qualified agencies or industry associations that can facilitate the activation process.
Challenge 4: Banking Restrictions
Unexpected banking requirements create further complications:
- Specific bank requirements vary by pilot zone (e.g., Chouzhou Bank in Yiwu)
- Certain branches in Shenzhen hold exclusive authorization
- Additional permissions required for account operations create barriers for new businesses
Solution: Research local banking requirements in advance and explore alternative authorization channels when necessary.
Conclusion: Navigating Policy 1039 Successfully
While implementing Policy 1039 presents multiple challenges, thorough preparation and strategic partnerships can help cross-border e-commerce sellers overcome these obstacles. Understanding the policy details and working with knowledgeable service providers remains key to accessing the benefits of this trade facilitation measure.