Provisions on Administration of Foreign Investment in International Maritime Transportation

文章摘要 本规定规范外国投资者在华设立外商投资企业从事国际海上运输及辅助业务。明确外商投资可采用合资、合作形式经营国际船舶运输、代理、管理等业务,外方持股比例不得超过49%,且董事长和总经理由中方担任;国际海运货物仓储及自有船舶日常服务允许独资。设立程序需先经交通主管部门审批,再经商务主管部门批准,完成工商登记后取得相应经营许可或登记。本文对跨境投资者评估准入条件、股权结构安排及审批流程具有重要指引价值。

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

外国投资者可以以哪些形式投资国际海运及其辅助业务?

根据规定,外商投资国际海运业务的形式按业务类型严格区分。国际船舶运输、国际船舶代理、国际船舶管理、国际海运货物装卸以及国际海运集装箱站与堆场业务,只能采用中外合资经营或中外合作经营形式;而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,则允许设立中外合资、中外合作或外商独资企业。该分类体现了对核心运输环节的持股限制与对辅助服务环节的开放取向。具体而言,对于国际船舶运输和国际船舶代理,外方投资比例均不得超过49%,且合资企业的董事长和总经理由中方指派。例如,国际船舶运输企业还须拥有适合国际运输的船舶且含中国籍船舶,并具备提单、客票或多式联运单证;国际船舶代理企业则须至少两名具有三年以上国际海运业务经验的高级管理人员。实务中,投资者应首先判断拟经营业务属于限制类还是允许类,据此设计股权结构和治理架构。若从事船舶运输或代理,外方不能控股,且需预留中方管理职位。注意独资仅适用于仓储和自有船舶日常服务,不可错误选择独资形式。建议在投资前对照业务范围逐项核验,避免因投资形式选择不当导致审批失败。

设立外商投资国际船舶运输企业需要满足哪些核心条件?

国际船舶运输企业属于外商投资限制领域,必须采取合资或合作形式。核心条件包括:拥有适于国际运输的船舶,其中必须有中国国籍船舶;船舶符合国家海上交通安全技术标准;具备提单、客票或多式联运单证;高管具备交通主管部门规定的职业资格。此外,外方投资比例不得超过49%,董事会董事长与总经理由中方协商后指派,这些条件确保中方在关键决策和运营中占据主导地位。根据规定,设立此类企业须遵循双重审批程序。申请人应先向交通主管部门提出申请,获得批准文件后,再凭该批准文件向商务主管部门提交规定所列材料,申办外商投资企业批准证书。取得批准证书后办理工商登记并取得营业执照,最后凭营业执照向交通主管部门申领国际船舶运输经营许可证,未取得该许可证不得从事国际船舶运输服务。整个审批链条完整且顺序不可颠倒。实务中,投资者需特别注意外方股权比例不得超过49%,并在合资合同中明确中方对董事长和总经理的提名权。船舶国籍与技术标准属于硬性条件,建议提前准备船舶所有权证书及检验证书。同时应预留充足审批周期,因为涉及交通与商务两个主管部门以及多个环节,申报材料务求齐全,避免因单证缺失或股权结构不合规而延误项目进度。

设立外商投资国际船舶代理企业的条件和审批流程有何特殊要求?

国际船舶代理企业同样属于外资受限业务,仅允许采用合资或合作形式,外方投资比例上限为49%。与船舶运输企业不同,船舶代理企业的条件侧重人员资质和设施能力,要求至少两名具有三年以上国际海运业务经营经验的高级管理人员,且该高管须为中国公民并具有中等以上技术职称或学历,在企业中担任部门经理及以上职务。同时须有固定营业场所和必要设施,并具备与港口、海关等部门进行电子数据交换的能力。在审批流程上,船舶代理企业采用先交通后商务的双轨审批。申请人先向交通主管部门申请,获批后向商务主管部门申办外商投资企业批准证书,随后办理工商登记取得营业执照,最后凭营业执照向交通主管部门申领国际船舶代理业务登记,取得登记后方可正式开展经营。该流程与船舶运输企业类似,但最终取得的证件为登记而非许可证,两者性质和法律效力存在差异。实务操作中,船舶代理企业的高级管理人员条件较容易被忽视,尤其是中国国籍和业务经验要求,外资方在提名高管时应确保人选完全符合规定。由于外方比例不超过49%,中方在董事会中拥有较强话语权,合作协议应明确决策机制。此外,电子数据交换能力属于硬性要求,信息化系统投入需提前规划。建议投资者在项目启动前与交通主管部门预沟通,确认拟设企业名称、经营范围及高管资质,以减少审批障碍并缩短筹备周期。

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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