The document pack from a prospective Chinese supplier usually arrives complete: business licence (营业执照), ISO 9001 certificate, a certificate of analysis, bank details, factory photographs. Nothing in it is obviously wrong, and that is the problem — a complete pack is not the same as a verified supplier. The single most useful sentence we can offer before the checklist starts is this one: verification across three consecutive production lots is a buyer requirement, not a legal or ISO obligation. If it is not written into the contract, no supplier is obliged to do it, and in practice none volunteer it. The same logic runs through everything below. Almost every item worth checking is something the buyer has to ask for by name.
The problem: the pack is complete and the checklist is out of date
Two items that buyers still ask for no longer exist.
The foreign trade operator record filing (对外贸易经营者备案登记) was abolished when the Standing Committee of the National People's Congress amended the Foreign Trade Law on 30 December 2022, deleting Article 9. Commerce authorities stopped accepting filings the same day. A company incorporated after that date has no such document, and asking for one signals that the buyer's diligence list has not been revised in nearly four years.
Dual-use exporter pre-registration went the same way. Under the Regulations on Export Control of Dual-Use Items (State Council Order No. 792), promulgated 19 October 2024 and effective 1 December 2024, an exporter no longer registers in advance as a dual-use exporter; it applies for the licence directly. A "dual-use exporter registration certificate" is not a document to request.
The second difficulty is access. The authoritative source on Chinese corporate records is the National Enterprise Credit Information Publicity System (国家企业信用信息公示系统, GSXT), operated by the State Administration for Market Regulation and free to use. From outside China it is frequently slow or unreachable, it gates queries behind a sliding-puzzle CAPTCHA that fails repeatedly on overseas IP addresses and mobile devices, and it has no English interface. The commercial databases that resell the same data added their own barriers: from around April 2023 one major provider began requiring a Chinese mobile number from overseas users, and another does not open outside mainland IP ranges. For a Korean buyer working alone, the primary verification route is effectively closed, which is why so much diligence stops at whatever the supplier chose to send.
Why the documents prove less than they appear to
Registered capital was a promise, not a payment. China ran a subscription system (认缴制) under which shareholders committed to a capital figure without being required to pay it in, so a company showing RMB 100 million of registered capital could hold nothing. The Company Law amended in 2023 and effective 1 July 2024 changed this: Article 47 requires shareholders of a limited liability company to pay up the subscribed capital in full within five years of incorporation. SAMR's implementing rules were promulgated on 20 December 2024 and took effect on 10 February 2025. Companies incorporated before 1 July 2024 whose remaining contribution period exceeds five years measured from 1 July 2027 must adjust that period by 30 June 2027, and joint stock companies must complete payment of share capital by the same date. A company that fails to do so is placed under separate administration, excluded from active-enterprise statistics, and has that fact published on GSXT. From the second half of 2027, in other words, GSXT disclosure becomes a free screening signal in its own right.
Business scope (经营范围) is a signal, not a boundary. Since the 2021 "separating permits from licences" (证照分离) reform, the scope printed on a business licence is written in two blocks: general items, which may be carried on under the licence alone, and licensed items, which require a separate permit before the activity may actually be conducted. The licence does not show whether that permit was ever issued. In materials, the permits that matter are the hazardous chemicals operating licence (危险化学品经营许可证) on the trading side and the hazardous chemicals safety production licence (危险化学品生产企业安全生产许可证) on the manufacturing side; if the material is a hazardous chemical, the business licence on its own proves nothing about the right to handle it. The reform cut the other way too: business activity outside the registered scope, where no permit is required, is no longer a punishable offence. So "it isn't in their scope, therefore they can't sell it" is not a valid inference either.
A factory audit is not a materials test. Third-party inspectorates such as SGS, Bureau Veritas, TÜV and Intertek audit documented procedures, QC processes, equipment and production capacity — the system that makes the goods. Visual inspection cannot establish chemical composition, long-term durability, or compliance with restricted-substance rules; that needs separate testing. Undisclosed subcontracting can also sit outside the audit boundary. For powder and ceramic feedstock this distinction decides where money goes: a factory audit answers "does this company exist and can it produce," while composition, purity and particle size are established only by lot testing and the buyer's own incoming inspection. Buyers routinely treat one as evidence of the other.
Signatures do not bind the way chops do. Company chops (公章) are registered with the Public Security Bureau (公安局), and Chinese courts have long practice in ruling on their authenticity, while there is no established method for authenticating a foreign signature. A contract carrying signatures but no chop is difficult to litigate in China.
The checklist
Each item below is stated as what to request, what it establishes, and what it does not. Where an item is industry custom rather than a legal requirement, it says so.
Legal existence and capacity
A 15-digit pre-2015 business registration number offered in place of a USCC means the document is old or was never refreshed. If the registration region in digits 3–8 does not correspond to the plant location the supplier claims, that is a question to ask rather than a finding — registering in one place and producing in another is lawful and common. Distinguishing a manufacturer from a trading company by paperwork alone is likewise industry custom, not a legal test, and the signals used for it (production verbs in the scope, an industrial-park address, production-side export rebate treatment, environmental and safety permits) are individually inconclusive. A manufacturer that exports through a separate trading entity is a normal tax and risk structure. The question worth asking is not "are you a trading company" but "what control does the contracting party hold over the production site," and that is answered by audit and contract, not by documents.
Export capability
Licence lead time belongs in the contract rather than in the schedule assumptions. The drafting point — that the trigger must be a deadline rather than a refusal, because indefinite silence is a more common outcome than a written rejection — is worked through in our note on procurement under export licensing. Control scope in critical minerals has moved repeatedly since October 2025, with measures introduced, some suspended and some given a year's grace, and we do not attempt to state here what is in force today. Check the announcement in force on the date you order, and price the review period into the contract rather than the forecast.
Quality documentation
The most efficient fraud check on this list costs nothing. Put three to five lots' COA values side by side in a spreadsheet. Real analytical results scatter; if every parameter sits exactly on the specification limit, or several lots report identical numbers, the values were copied from a catalogue or invented. Certificate verification has a matching three-step form: check that the site address on the certificate is the plant that will actually produce your material, check that the scope wording covers your item's process, and look the number up in the relevant database to confirm the status is valid. Certificates that look correct in PDF but return as withdrawn on lookup, and certificates covering a different plant in the same group, are both reported patterns. What a COA cannot substitute for is measurement: the protocol for confirming morphology, composition, particle size and phase on a received lot is set out in our SEM/EDS lot verification method, and the line items we ask a mill certificate to carry are listed on our SiC powders page.
Site verification
Capability overstatement — claiming equipment or capacity that belongs to another plant or does not exist — is the misrepresentation that documents are least able to catch, and walking every production area is the only reliable way to find it. What an auditor is there to do is count operating lines and workstations, read equipment nameplates against claimed capacity, confirm that the specific process your item needs exists and is running, look for undisclosed subcontracting in the production scheduling records, and check QC laboratory instruments for calibration status rather than mere presence.
Remote audit is a partial substitute and should be run on stricter terms than most buyers set. Video must be live; a pre-recorded walkthrough is not evidence. Conferencing tools are often unstable inside Chinese plants because of network filtering, so a channel that is reliable inside China is the practical choice. Insist on a continuous, unbroken floor walk rather than an edited showroom tour, and ask the supplier to open live ERP work orders and current QC records on screen share. We have seen a figure quoted for how much remote auditing misses relative to on-site work; we could not locate the underlying study and do not repeat the number. The qualitative point stands on its own — remote audit does not replace a site visit. Staging a plant for auditors, and the rented-showroom pattern in which a few machines and a sign are photographed and vacated weeks later, are both documented risks.
Contract, payment, and the buyer's own obligations
On contracts we recommend taking legal advice; what follows is procurement practice, not a legal opinion. Where a governing language is not specified, a Chinese court will work from the Chinese text or commission its own translation of an English contract, and enforceability suffers. Insisting on an English original does not avoid this — it means a translation you did not control is the one the court reads. The two language versions should be checked against each other for actual equivalence, because ambiguity introduced in translation is what makes enforcement difficult.
China's Arbitration Law was amended on 12 September 2025, effective 1 March 2026 — the first substantive revision since 1995. Two of its headline changes are narrower than they first look. Ad hoc arbitration is now allowed, but only for two defined categories of foreign-related dispute: maritime disputes, and disputes between enterprises registered in State-designated zones such as the free-trade pilot zones and the Hainan Free Trade Port. A materials buyer is typically in neither category, so the clause still needs a named arbitration institution. Foreign institutions such as the ICC and SIAC are permitted to conduct foreign-related arbitration business only in State Council-approved designated zones, not nationwide. The amendment also formally recognises the seat of arbitration, and commentators read it as meaning that awards from foreign-administered foreign-related arbitrations seated in China are treated and enforced as domestic awards. Commentary on the amendment is divided, and at least one arbitration practice has characterised it as a step back after two steps forward, so we do not present it as a settled improvement. The procurement conclusion is unaffected by that debate: if the counterparty's assets are in China, enforcement ends in China whichever forum is chosen, which puts a Chinese-language original bearing a verified chop ahead of forum selection in order of importance.
Payment terms are the one control the buyer holds unilaterally. The common structure is a 30% T/T advance with the balance against shipping documents; a structure that keeps leverage — such as a smaller advance, a tranche released only on passing pre-shipment inspection, and a final tranche after arrival — leaves room to catch material substituted late in production. A letter of credit does not close this gap, and the misunderstanding is widespread enough to state plainly: banks examine documents, not goods. An L/C protects against non-shipment and document failure. It does not protect against material that arrives off specification. The instrument that does is a contract clause making payment conditional on passing pre-shipment inspection. How the resulting payment timing feeds through to working capital is covered in our note on inventory buffering and the cash conversion cycle.
Finally, several obligations sit with the buyer and cannot be delegated to the supplier's assurances.
- Sanctions and forced-labour screening. The UFLPA Entity List reached 187 entities with 43 added effective 3 August 2026, the largest single expansion since the statute took effect, and the full list is downloadable free from the US Department of Homeland Security. Screen on USCC rather than English name — transliteration variants and aliases defeat name matching. The list is US law and does not apply to a Korean buyer directly, but a route to the US market makes it a real exposure. We do not assess whether any particular company is listed; that is a screening step for the buyer to run against the current list on the date of the order.
- Carbon and battery reporting. The EU CBAM definitive period began on 1 January 2026, with the annual declaration and certificate surrender deadline extended to 30 September of the year following import under the CBAM Omnibus regulation, and importers at or below 50 tonnes a year exempt. Liability sits with the EU importer, but the embodied-emissions data originates upstream — which means an obligation to supply emissions data has to be in the purchase contract, because there is no way to obtain it retroactively. Battery Regulation due diligence obligations were postponed two years to 18 August 2027, with the guidelines deadline moved to 26 July 2026; the postponement lengthens the preparation window rather than removing the requirement.
- Korean strategic-items classification. Classification is either self-classification by the trader or expert/advance classification by a designated body, against the annexes of the Public Notice on Trade in Strategic Items. The administering body was renamed and is now 무역안보관리원, abbreviated KOSTI — the former 전략물자관리원 no longer exists under that name — and classification runs through the yesTrade system. There is no statutory expiry on a self-classification, but the Public Notice is amended annually and controlled items and specifications change with it, so last year's non-strategic determination is not this year's basis. Transit and transhipment of controlled goods through Korean ports and airports requires its own permit. Re-export exemptions exist in the consolidated notice, but we could not confirm the substance of those provisions in this research and do not summarise them here.
- Import requirements and chemical registration. Customs-head confirmation of import requirements is keyed to the HS classification, so until the HS code is settled the applicable requirements are not settled either, and the designating notice is revised to track HSK changes. K-REACH registration and reporting duties fall on the Korean importer, not the Chinese producer: a supplier's assurance that its product "has no issues" has no standing under Korean law. Confirm the CAS number, check it against the existing-substances inventory, calculate annual import volume, and appoint an only representative if that route is used. The volume thresholds are stated inconsistently across the secondary sources we reviewed and we do not reproduce a figure here; the working guide for classification and Korean import requirements on a specific material is our SiC powder import guide.
For Korean buyers locked out of the Chinese databases, there is a practical detour worth knowing: KOTRA runs buyer credit investigations through its overseas trade office network, and K-SURE offers overseas company credit reports — Korean trade press has reported the fee at KRW 33,000 for SMEs and mid-tier companies and KRW 66,000 for large enterprises. Order the report before the contract is drafted, at the latest during quotation. After shipment there is nothing left to prevent.
Frequently asked questions
Does a large registered capital mean the supplier is financially sound?
No, and historically it has meant very little. Under the subscription system a company could register any capital figure without paying it in. The 2024 Company Law amendment imposes a five-year payment deadline and a 30 June 2027 transitional date for companies incorporated earlier, which will make the figure more meaningful over time. Until then, read the paid-in amount on GSXT rather than the registered amount, and judge financial substance from audited financials, annual reports and tax credit rating.
Should we refuse to deal with a trading company?
No. A manufacturer exporting through a separate trading entity is a normal structure adopted for tax, rebate and risk reasons. The distinction that matters is what control your contracting counterparty holds over the production site, and whether the party you can sue is the party responsible for quality. Ask for the production site to be named in the contract and for the quality obligation to sit with your counterparty regardless of which entity appears as shipper.
Is an ISO 9001 certificate enough to qualify a supplier?
It is a screening step. It shows a management system passed audit at a point in time, and nothing about current operation, financial condition, labour practice, or the properties of the material you will receive. Check the site address and scope wording against your own order, confirm the status by database lookup, and verify material properties separately by lot testing.
Do we have to require three consecutive lots?
You do not have to, and nothing requires the supplier to provide them unless you ask. Three-lot verification is a buyer requirement widely used in automotive PPAP practice, adopted because reproducibility cannot be judged from a single lot. Its cost is real — three production runs before approval lengthens qualification — so decide deliberately, and if you decide to require it, write it into the contract with the sampling basis and the acceptance criteria attached.
References (public sources)
- National Enterprise Credit Information Publicity System (GSXT), operated by the State Administration for Market Regulation — the authoritative free source for registration, penalties, annual reports and abnormal operations listings; accessed August 2026.
- Chinese standards documentation on the Unified Social Credit Code — the five-segment structure, digit positions and excluded characters. English-language secondary sources differ on the digit positions; we follow the Chinese-language standard documentation.
- Company Law of the PRC as amended 2023, effective 1 July 2024, Article 47; SAMR implementing rules promulgated 20 December 2024, effective 10 February 2025; international law firm commentary, 2024–2025, on the transitional deadline of 30 June 2027 and the consequences of non-compliance.
- State Council document on the 2021 reform separating permits from business licences — the general items and licensed items blocks, and the treatment of activity outside the registered scope.
- Ministry of Emergency Management measures on hazardous chemicals operating licences, and provincial administrative service listings for the hazardous chemicals safety production licence.
- Ministry of Commerce announcement on the deletion of Article 9 of the Foreign Trade Law, and Chinese press coverage, December 2022 — abolition of foreign trade operator record filing.
- Regulations on Export Control of Dual-Use Items (State Council Order No. 792), promulgated 19 October 2024, effective 1 December 2024, with law firm commentary — licence types and the abolition of exporter pre-registration.
- Chinese customs enterprise credit rating system — the five rating tiers, from a municipal AEO guide and industry commentary.
- A municipal government publication, January 2025 — the share of advanced-certified enterprises at under 0.3% of all registered enterprises.
- IAF CertSearch and its FAQ, and IATF customer portal documentation — certificate verification routes, and the statement that accreditation is not mandatory.
- Industry guidance on certificate of analysis content and on distinguishing reported lot data from catalogue typical values.
- AIAG PPAP guidance summaries and quality-profession discussion of whether three production lots are a manual requirement — cited as evidence that the point is contested, not settled.
- Third-party inspection industry material on what a factory audit covers and does not cover, including the limits of visual inspection and the exposure to undisclosed subcontracting.
- Chinese company chop practice: law firm notes on the company chop, contract chop and legal representative chop, and on Public Security Bureau registration of chops.
- Amended PRC Arbitration Law, passed 12 September 2025, effective 1 March 2026, with commentary from several international arbitration practices, including one dissenting assessment — ad hoc arbitration, foreign institutions, seat, and enforcement of foreign-administered awards seated in China.
- Trade practice guidance on T/T payment structures and on the documentary nature of letters of credit.
- US Department of Homeland Security UFLPA Entity List and law firm coverage of the expansion effective 3 August 2026.
- EU CBAM Omnibus Regulation (EU) 2025/2083, in force 20 October 2025, and advisory commentary on the definitive period from 1 January 2026; Council of the EU press release, 18 July 2025, on the two-year postponement of Battery Regulation due diligence obligations to 18 August 2027.
- KOSTI (무역안보관리원) guidance on strategic item classification and the yesTrade system; Korean statutory information portal on transit and transhipment permits.
- Korea Customs Service material on the customs-head confirmation system and its revision to track HSK changes; K-REACH overview material from the Chemical Substances Information Processing System and testing bodies.
- KOTRA and K-SURE service descriptions on overseas buyer credit investigation, with fee figures as reported in Korean trade press.
Figures and legal positions above reflect public sources as of the time of writing. Export control scope for critical minerals and the UFLPA list in particular change frequently, and should be checked on the date of the order rather than taken from this article.
Nami Tech Solutions (NTS) does the part of this list that cannot be done from Korea. We deal with the manufacturer directly in Chinese, read the mill certificate for each lot against the specification that was agreed rather than against a catalogue, and structure the order so that payment follows inspection of the material at a designated address in China — which means a non-conforming lot can be physically refused before it moves, rather than argued about after it lands.
