1. The general position
An export licence is not transferable.
Only the holder can export.
2. The consequences
The licence must be in the exporter’s name
The named exporter does not have to be the producer.
The transaction terms
Where a third party buys and re-exports, the licence has to be in that party’s name.
The consignee
Some categories permit substitution within limits. Most do not.
3. The trading company problem
A trading company exports goods made by a factory.
The licence is in the trading company’s name.
The factory’s details appear in the supporting documents.
4. The consignee substitution question
Some destinations and categories permit a consignee substitution without a new licence.
5. The scenario
A trading company applied for a licence in the factory’s name, expecting the factory to export.
The factory was not a registered exporter and could not complete the declaration.
6. The lesson
The licence follows the party that files the declaration.
7. The check
Confirm the named exporter on the declaration matches the licence holder.
8. Closing view
Licence administration is tied to the legal person, not to the goods alone.
*This article is based on China’s export licensing administration.*