Provisions on Administration of Foreign Investment in International Maritime Transportation

文章摘要 本文系统梳理了外商投资国际海运业的管理规定,明确了外商在中国境内投资经营国际海运及其辅助业务的法定形式、准入条件与审批流程。核心要点包括:外资可通过合资、合作或独资方式进入国际海运相关领域,但国际船舶运输与国际船舶代理业务须采用合资或合作形式,且外资持股比例不得超过49%;企业设立需满足船舶国籍、技术标准、高管资质等硬性条件,并遵循交通运输主管部门与商务主管部门双重审批、先批后证的程序要求。文章对跨境投资人合规进入中国海运市场具有重要实务指导价值。

Article 1  These Provisions are formulated in accordance with the Regulations of the People’s Republic of China on International Maritime Transportation (hereinafter referred to as the Maritime Transportation Regulations) and the relevant laws and administrative regulations of the People’s Republic of China on foreign investment, for the purposes of regulating the establishment of foreign-funded enterprises by foreign investors to engage in international maritime transportation business and auxiliary business relating thereto and safeguarding the lawful rights and interests of Chinese and foreign investors.


Article 2  These Provisions are applicable to the investment in and operation of international maritime transportation business and auxiliary businesses relating thereto (hereinafter referred to as international maritime transportation) by foreign investors within the territory of China.


Article 3  The Ministry of Communications and the Ministry of Commerce of the People’s Republic of China as well as their authorized agencies are responsible for the approval and administration of the establishment of foreign-funded enterprises within the territory of the People’s Republic of China by foreign investors to engage in international maritime transportation.  


Article 4  With the approval of the Ministry of Communications and the Ministry of Commerce, a foreign investor may invest in and operate international maritime transportation in the following forms:


(1) to establish a Chinese-foreign equity joint venture or a Chinese-foreign contractual joint venture to engage in international shipping services, international shipping agency services, international ship management services, loading and unloading of international shipments and international maritime container freight station and container yard services;


(2) to establish a Chinese-foreign equity joint venture, a Chinese-foreign contractual joint venture or a wholly foreign-owned enterprise to engage in international maritime cargo warehousing services;


(3) to establish a Chinese-foreign equity joint venture, a Chinese-foreign contractual joint venture or a wholly foreign-owned enterprise to offer routine services for the vessels owned or operated by the investor. 


Article 5  A foreign-funded international shipping enterprise to be established shall meet the following conditions:


(1) having vessels suitable for employment in international maritime transportation, among which there must be vessels of Chinese nationality;


(2) vessels under employment shall be in compliance with the technical standards for maritime traffic safety as set forth by the State;


(3) having bills of lading, passenger tickets or multimodal transportation documents;


(4) having senior executives with the professional qualifications as set forth by the Ministry of Communications;


(5) in case of establishing a Chinese-foreign equity joint venture or a Chinese-foreign contractual joint venture, the proportion of investment made by foreign investors shall not exceed 49%;


(6) the chairperson of the board of directors and the general manager shall be appointed by the Chinese side after consultation between the both sides;


(7) other conditions specified by laws or administrative regulations. 


Article 6  Where anyone is to establish a foreign-funded enterprise to engage in international shipping services, it shall firstly make an application to the Ministry of Communications in accordance with the provisions of the Maritime Transportation Regulations and the Implementing Rules of the Regulations of the People’s Republic of China on International Maritime Transportation (hereinafter referred to as the Implementing Rules of the Maritime Transportation Regulations); if such application is approved by the Ministry of Communications, the applicant shall, in accordance with the laws and administrative regulations on foreign investment of the State and on the strength of the approval document issued by the Ministry of Communications, go through the approval procedures for establishing a foreign-funded enterprise with the Ministry of Commerce by submitting the documents specified in Article 15 of these Provisions and obtain the Approval Certificate for Foreign-funded Enterprise.


The applicant shall, by presenting the approval document issued by the Ministry of Communications, the Approval Certificate for Foreign-funded Enterprise issued by the Ministry of Commerce and other relevant documents, go through the industrial and commercial registration formalities with the administrative department for industry and commerce according to law and obtain the business license.


 After the establishment of a foreign-funded international shipping enterprise, the applicant shall, by presenting the business license issued by the administrative department for industry and commerce, apply to the Ministry of Communications for obtaining the Permit for Operation of International Shipping Services. Only those that have obtained such Permit may engage international shipping services. 


Article 7  A foreign-funded international shipping agency enterprise to be established shall meet the following conditions:


(1) having at least two senior executives with no less than three years’ experience in international maritime transportation business operations. The term “senior executives” refers to Chinese citizens who have secondary or higher technical or academic titles and serve as department managers or above in enterprises engaging in international maritime transportation business or the auxiliary business relating thereto;


(2) having a fixed place of business and necessary business facilities, including the ability to have electronic data interchange (EDI) with ports, the Customs and other departments;


(3) in case of establishing a Chinese-foreign equity joint venture or a Chinese-foreign contractual joint venture, the proportion of investment made by foreign investors shall not exceed 49%;


(4) other conditions specified by laws or administrative regulations. 


Article 8  Where anyone is to establish a foreign-funded enterprise to engage in international shipping agency services, it shall firstly make an application to the Ministry of Communications in accordance with the provisions of the Maritime Transportation Regulations and the Implementing Rules of the Maritime Transportation Regulations; if such application is approved by the Ministry of Communications, the applicant shall, in accordance with the laws and administrative regulations on foreign investment of the State and on the strength of the approval document issued by the Ministry of Communications, go through the approval procedures for establishing a foreign-funded enterprise with the Ministry of Commerce by submitting the documents specified in Article 15 of these Provisions and obtain the Approval Certificate for Foreign-funded Enterprise.


The applicant shall, by presenting the approval document issued by the Ministry of Communications, the Approval Certificate for Foreign-funded Enterprise issued by the Ministry of Commerce and other relevant documents, go through the industrial and commercial registration formalities with the administrative department for industry and commerce according to law and obtain the business license.


After the establishment of a foreign-funded international shipping agency enterprise, the applicant shall, by presenting the business license issued by the administrative department for industry and commerce, apply to the Ministry of Communications for obtaining the Registration for Operation of International Shipping Agency Services. Only those that have obtained such Registration may engage international shipping agency services. 


Article 9  A foreign-funded international ship management enterprise to be established shall meet the following conditions:


(1) having at least two senior executives with no less than three years’ experience in international maritime transportation business operations;


(2) having staff members in possession of master’s or chief engineer’s documents of competence that are commensurate with the types of vessels under their management and the navigation zones;


(3) having the equipment or facilities commensurate with the international ship management services. 


Article 10  Where anyone is to establish a foreign-funded enterprise to engage in international ship management services, it shall firstly make an application to the Ministry of Communications in accordance with the provisions of the Maritime Transportation Regulations and the Implementing Rules of the Maritime Transportation Regulations; if such application is approved by the Ministry of Communications, the applicant shall, in accordance with the laws and administrative regulations on foreign investment of the State and on the strength of the approval document issued by the Ministry of Communications, go through the approval procedures for obtaining the Approval Certificate for Foreign-funded Enterprise with the competent commerce administration department of the people’s government of the province where such enterprise is to be located by submitting the documents specified in Article 15 of these Provisions.


After the establishment of a foreign-funded international ship management enterprise, the applicant shall, by presenting the business license issued by the administrative department for industry and commerce, apply to the competent communications administration department of the people’s government of the province where such enterprise is located for obtaining the Registration for Operation of Auxiliary Businesses Relating to International Maritime Transportation. Only those that have obtained such Registration may engage in international ship management services.


Article 11  Where anyone is to establish a foreign-funded enterprise to engage in international maritime container freight station and container yard services or international maritime cargo warehousing services, it shall firstly make an application to the Ministry of Communications in accordance with the provisions of the Maritime Transportation Regulations and the Implementing Rules of the Maritime Transportation Regulations; if such application is approved by the Ministry of Communications, the applicant shall, in accordance with the laws and administrative regulations on foreign investment of the State and on the strength of the approval document issued by the Ministry of Communications, go through the approval procedures for obtaining the Approval Certificate for Foreign-funded Enterprise with the competent commerce administration department of the people’s government of the province where such enterprise is to be located by submitting the documents specified in Article 15 of these Provisions.


After the establishment of a foreign-funded enterprise engaging in international maritime container freight station and container yard services or international maritime cargo warehousing services, the applicant shall, by presenting the business license issued by the administrative department for industry and commerce, apply to the competent communications administration department of the people’s government of the province where such enterprise is located for obtaining the Registration for Operation of Auxiliary Businesses Relating to International Maritime Transportation. Only those that have obtained such Registration may engage in the relevant services.


The establishment of a foreign-funded enterprise engaging in loading and unloading of international shipments shall be governed by the relevant provisions of the State.


Article 12  Where an established foreign-funded enterprise applies to add international maritime transportation business or the auxiliary business relating thereto to its business scope, it shall go through the corresponding formalities in accordance with the procedures for establishing a foreign-funded enterprise engaging in specific international maritime transportation businesses set forth in these Provisions.


Where an established foreign-funded enterprise engaging in international maritime transportation is to establish branches, it shall go through the corresponding formalities with the Ministry of Communications and the Ministry of Commerce or their authorized agencies in accordance with the laws and administrative regulations on foreign investment of the State, the Maritime Transportation Regulations and the Implementing Rules of the Maritime Transportation Regulations.


Where an established foreign-funded enterprise engaging in international maritime transportation is to modify the essential contents such as investment contribution, structure of the shares or scope of business of its contact of joint venture or articles of association, it shall go through the corresponding formalities with the Ministry of Commerce or its authorized agencies in accordance with the laws and administrative regulations on foreign investment of the State. Any modification to the matters specified in Article 21 of the Implementing Rules of the Maritime Transportation Regulations shall be filed with the Ministry of Communications for the record.


Article 13  A foreign company engaging in shipping may establish a Chinese-foreign equity joint venture, Chinese-foreign contractual joint venture or wholly foreign-owned enterprise to offer such routine services as canvassing of cargoes, issuance of bills of lading, settlement of freight and signing of service contracts for the vessels owned or operated by investors. The procedures for establishment application of such an enterprise shall be governed by the relevant provisions jointly issued by the Ministry of Communications and the Ministry of Commerce on approval of establishment of wholly foreign-owned shipping companies.


Article 14  Where a foreign-funded enterprise within the territory of China is to engage in non-vessel-operating services, it shall, in accordance with the provisions of the Maritime Transportation Regulations and the Implementing Rules of the Maritime Transportation Regulations, make an application to the Ministry of Communications for registration and obtaining the Registration of Non-vessel-operating Services Qualification, and go through the approval formalities with the Ministry of Commerce in accordance with the relevant laws and administrative regulations on foreign investment of the State. 


Article 15  Where an applicant makes an application to the Ministry of Communications, it shall submit the documents specified in the Maritime Transportation Regulations and the Implementing Rules of the Maritime Transportation Regulations. Where an applicant makes an application to the Ministry of Commerce or its authorized agencies, he shall submit the following documents:


(1) the letter of application;


(2) the feasibility study report;


(3) the contract of the joint venture and the articles of association of the company (in case of a wholly foreign-owned company, the articles of association of the company only);


(4) the registration certificate and credit-standing certificate of investors;


(5) the identity certification of the chairperson of the board of directors and the general manager of the enterprise to be established;


(6) other documents required by laws or administrative regulations.


Article 16  These Provisions are mutatis mutandis applicable to the establishment of enterprises engaging in international maritime transportation and the auxiliary services relating thereto in other provinces, autonomous regions or municipalities directly under the Central Government by the investors form Hong Kong Special Administrative Region, Macao Special Administrative Region or Taiwan region.


Article 17  In accordance with the relevant provisions of the Mainland and Hong Kong Closer Economic Partnership Arrangement, the Mainland and Macao Closer Economic Partnership Arrangement and their Annexes, from January 1st, 2004, service suppliers from Hong Kong or Macao may established a wholly Hong Kong or Macao-owned enterprise in Chinese mainland to engage in international ship management services, international maritime cargo warehousing, international maritime container freight station and container yard services, and non-vessel-operating services; they may also establish a wholly Hong Kong or Macao-owned shipping company in Chinese mainland to offer such routine services as canvassing of cargoes, issuance of bills of lading, settlement of freight and signing of service contracts for their owned or operated vessels.  


Article 18  The Ministry of Communications and the Ministry of Commerce are responsible for the interpretation of these Provisions.


Article 19  These Provisions shall take effect as of June 1st, 2004.

杨春宝一级律师简介

杨春宝一级律师,大成上海高级合伙人、资本市场部主任、国资基金研究中心主任,大成中国区私募基金专业带头人、科技与文化法律研究中心联合牵头人。执业30余年,长期从事私募基金、投融资、并购重组法律服务,尤其对对赌研究颇深且具有非常丰富的实战经验,并专注于金融机构股权投资业务。2004年起多次入选The Legal 500"私募基金"和"公司与商业"等境内外各类律师榜单,代理的中国法院首例适用外国法律审理外国公司的董事损害小股东权益纠纷案入选上海高院发布的《上海法院域外法查明典型案例》和威科先行"要案头条"。入选上海涉外法律人才库、上海市司法局鼎新法治人才库、上海国有企业改制法律顾问团,具有上市公司独立董事任职资格,系多家知名高校的兼职教授或兼职研究生导师及上海市商务委跨国经营人才培训班讲师。出版《私募股权投资基金风险防控操作实务》等16本投融资法律专著。了解更多

常见法律问题

外商投资国际海运可采用哪些企业形式?

根据现行管理规定,外国投资者投资中国国际海运业务的企业形式依业务类型有所区分。对于国际船舶运输、国际船舶代理、国际船舶管理、国际海运货物装卸、国际海运集装箱站与堆场业务,外国投资者只能设立中外合资经营企业或中外合作经营企业,不能设立外商独资企业。而对于国际海运货物仓储业务,以及为投资者自有或经营的船舶提供日常服务,法律允许设立中外合资、中外合作乃至外商独资企业。需要特别注意的是,在设立中外合资或合作企业从事国际船舶运输或国际船舶代理业务时,外资持股比例不得超过49%,且企业董事会董事长和总经理应由中方投资者协商后委派。这一比例限制体现了国家对关键海运服务领域的准入控制,旨在保障国家航运安全与产业主导权。实务中,投资人应在项目启动前充分评估业务类型与股权结构,避免因形式选择错误导致审批受阻。此外,各业务类型对应的审批机关均为交通运输主管部门与商务主管部门,但国际船舶运输企业最终还需取得国际船舶运输经营许可证,而国际船舶代理企业则需办理国际船舶代理经营资格登记,二者法律性质不同,企业应区分申请路径。

设立外资国际船舶运输企业需满足哪些条件?

设立外商投资国际船舶运输企业需同时满足多项实质条件。首先,企业必须拥有适合从事国际海运的船舶,且其中必须包含中国国籍船舶,这是保障本国船队参与国际运输的刚性要求。其次,投入运营的船舶必须符合国家规定的海上交通安全技术标准,确保航行安全与环保合规。第三,企业应具备提单、客票或联运单证,这是开展国际运输业务的必备业务文件。第四,企业须配备具有交通主管部门规定专业资质的高级管理人员。第五,若采用中外合资或合作形式,外资出资比例不得超过49%,且董事会董事长和总经理应由中方协商后任命。第六,须满足法律行政法规规定的其他条件。实务中,中国籍船舶的登记与检验、外籍船舶的租入与挂旗安排,以及高管人员资质的认定,往往是审批中的重点难点。企业应在申请前完成船舶采买或租赁协议、船员管理与技术标准符合性证明、单证样本、高管简历及资质证书等文件的准备。此外,审批采取两步走模式:先向交通运输主管部门申请业务许可,取得批准文件后再向商务主管部门申请外商投资企业设立审批,最后凭两部门文件办理工商登记并申领经营许可证。任何环节缺失或材料瑕疵都可能导致审批周期延长,建议企业借助专业法律与航运顾问进行全流程筹划。

外资国际船舶代理企业的设立条件与审批程序如何?

外资国际船舶代理企业的设立条件相对聚焦于管理人员与运营设施。具体而言,企业须至少配备两名具有三年以上国际海运业务运营经验的高级管理人员,此处高级管理人员指具有中级及以上技术职称或同等学历、在企业中担任部门经理及以上职务的中国公民。同时,企业须拥有固定的经营场所和必要的业务设施,包括能够与港口、海关等部门进行电子数据交换(EDI)的能力,以满足现代船舶代理信息化监管要求。与船舶运输企业相同,若设立合资或合作代理企业,外资持股比例不得超过49%。审批程序上,申请人应先向交通运输主管部门提交设立申请,依据国际海运条例及其实施细则的规定获得批准文件,然后凭批准文件向商务主管部门报送外商投资企业设立审批材料,取得外商投资企业批准证书,再办理工商登记领取营业执照。与运输企业不同的是,船舶代理企业在设立后并非申领经营许可证,而是向交通运输主管部门办理国际船舶代理经营资格登记,取得登记证明后方可正式开展代理业务。这一差异意味着代理业务的行政管控更侧重于资格登记而非许可准入,但同样具有强制性。实务中,企业须注意高级管理人员的劳动关系与社保记录证明,以佐证其从业年限,同时提前完成EDI系统建设或第三方服务协议签署。常见争议集中在高管经验认定、外资间接持股是否穿透计算比例等问题,建议在申请前与审批机关进行预沟通。

以上内容仅供参考,不构成法律意见。如需专业法律服务,请联系杨春宝一级律师:chambers.yang@dentons.cn

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