Designed to address the common challenge of non-invoiced procurement in cross-border e-commerce, China's 1039 market procurement trade policy was meant to be a game-changer. However, the reality has proven more complex than anticipated, with many sellers reporting significant implementation barriers.
Pilot Registration and Filing: Information Asymmetry and Complex Procedures
The first hurdle requires sellers to register individual businesses and complete 1039 filings in designated pilot cities. Requirements vary significantly between cities, involving multiple platforms including market procurement information systems, customs declaration systems, and logistics networks. Compounding the problem, service providers often lack comprehensive knowledge of operational details, leaving sellers without proper guidance from the outset.
Logistics Provider Challenges: Knowledge Gaps and Established Practices
Finding cooperative and knowledgeable logistics partners presents another major obstacle. Many freight forwarders either misunderstand the policy or hesitate to adopt new procedures. Even willing partners may lack practical experience, leading to non-compliant processes. Some sellers report cases where forwarders insisted on unnecessary routing—such as requiring goods filed in Shenzhen to physically pass through the city before Shanghai exports—adding unnecessary costs and delays.
Single Window Protocol Activation: Qualification Barriers and Channel Dependencies
The export agency agreement requires activation through China's Single Window system, which demands specific qualifications. Newly established companies typically lack these credentials, forcing them to seek special authorization channels that increase both complexity and operational expenses.
Bank Account Restrictions: Pilot Requirements and Authorization Hurdles
Certain pilot cities impose strict banking requirements—Yiwu mandates using Chouzhou Bank, Dongguan specifies local banks, while Shenzhen currently restricts account openings to particular branches. Beyond basic accounts, sellers need additional permissions including pre-collection whitelisting and various transfer authorizations. New companies often fail to meet banks' stringent qualification reviews, requiring intermediary channels to secure necessary permissions.
Potential Solutions: Professional Services and Policy Literacy
Despite these challenges, specialized service providers are emerging with comprehensive 1039 solutions covering registration, logistics coordination, system activation, and banking requirements. Simultaneously, sellers must deepen their policy understanding and proactively engage with relevant authorities to fully leverage the program's benefits.
Balancing Opportunity and Implementation
While the 1039 policy offers cross-border e-commerce sellers new operational possibilities, its current implementation challenges require careful navigation. Success demands both thorough policy comprehension and strategic adaptation. Businesses that invest in proper support and process optimization stand to gain significant competitive advantages in this evolving trade landscape.