📌 Sellers with annual sales exceeding 10 million—you need to give this some serious thought.

If your annual sales have already reached10 million or more...If you run multiple stores and manage multiple sites, you’ve probably been bombarded with all kinds of feedback lately—

“Following Route 9810 is the most compliant way!”

“0110 is outdated and non-compliant!”

“Amazon sellers must use Form 9810, or the tax authorities will investigate you!”

Some of the people who say these things sell courses, while others sell services, but very few of them have actually done the math for you:Given your business scale, number of stores, team structure, and funding sources, which path is right for you?

I’ve seen too many sellers with annual sales in the tens of millions who, after hearing that ”9810 is the most compliant,” went back and completely overhauled their entire structure, only to find that tax refunds weren’t possible, the financial workload exploded, and they had to keep separate books for each of their dozens of store companies—The business didn’t go under—compliance killed it first.

I’ve also come across another type of seller who strictly adheres to the 0110 model but has only copied the ”shell” of the Saisi model—multiple stores plus a Hong Kong-based company—yet the profits aren’t being repatriated, the funds are going into personal pockets, the stores report zero revenue, and the figures don’t match the platform’s data at all.As soon as Document No. 15 took effect, I received a text message from the tax office.

To put it simply, neither 0110 nor 9810 is more compliant than the other.
Whether it is compliant or not depends on whether your method of customs declaration matches the substance of the transaction.

In today’s article, the Qicaiying editorial team will explain 0110 and 9810 in detail: what they actually are, how they differ, which types of sellers they’re suitable for, and which types they’re not suitable for.Business owners of cross-border e-commerce companies with annual sales exceeding 10 million—read this and decide for yourself.

If you’re also in the cross-border e-commerce business and want to transition to compliance but don’t know how, feel free to scan the QR code to contact Qicaiying’s online customer service (WeChat ID: jxhqcy890 / Mobile: 16625410105) 👉 Based on your specific situation, we’ll arrange for a professional consultant to address your questions and provide one-on-one, end-to-end compliance solutions.

01 First, let's understand: What exactly are 0110 and 9810?

0110: General Trade

0110, formally known as ”General Trade,” is currently the most widely used and well-established method of customs clearance and supervision.

Simple to understand:You sell a large batch of goods in a single transaction to an overseas company (B2B transaction) and declare the export using code 0110. For cross-border e-commerce sellers, the typical approach is for a domestic export company to purchase the goods and sell them through customs declaration using code 0110 toHong Kong company...and then Hong Kong-based companies sell them to overseas consumers through platforms such as Amazon.

Before the introduction of the new models—9610, 9710, and 9810—0110 was virtually the only option for cross-border e-commerce exports. Even now,Anker, Siva Times, Greenconn, ZhiouThese bestsellers are still processed under code 0110 for export tax rebates.

9810: Cross-border E-commerce Export to Overseas Warehouses

9810, whose full name is ”Cross-border E-commerce Export Overseas Warehouses,” is specifically designed for the overseas warehouse stocking model.

Core Processes:Domestic export companies ship goods in bulk directly to overseas warehouses (such as Amazon FBA warehouses). After the goods leave the country, they apply for a tax refund using the customs declaration form, and once overseas consumers place orders, the goods are shipped and delivered from the overseas warehouses.

Effective January 2025, 9810 introduced a new ”Pre-Departure Tax Refund” policy—as soon as goods clear Chinese customs, a preliminary tax refund of 70%-90% can be issued, with any overpayment or underpayment to be settled based on actual sales by April 30 of the following year.

⚠️ Sounds great, right? But in practice, the tax refund dilemma with the 9810 will be discussed in detail later.

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02 A Comprehensive Comparison Across 6 Dimensions: 0110 vs. 9810

Dimension 1: Goods Flow Path

Path 0110

Suppliers → Procurement by Domestic Export Companies → 0110 Customs Clearance for Export → Hong Kong company → Overseas Warehouses → Consumer Market

Route 9810

Supplier → Procurement by Domestic Export Companies → 9810 Export Customs Declaration → Ship directly to the overseas warehouse → Consumer (C-end)

The difference is this: In the 0110 model, a ”Hong Kong company” acts as an intermediary buyer; in the 9810 model, the export company ships directly to the overseas warehouse without involving a Hong Kong company.

Dimension 2: Practical Tax Refund Procedures

✅ 0110 Tax Refund

This process is the most well-established, and the tax authorities are most familiar with it. After customs clearance is finalized, standard documentation—such as input tax invoices and the export tax refund copy—is submitted, and Category 1 enterprises can receive their tax refunds within five business days.Listed companies like Anker and Suntech have all followed this path.

⚠️ 9810 Tax Refund

Although policies support ”pre-departure tax refunds,” in practice, local tax authorities do not apply consistent standards when reviewing 9810 tax refund applications. Many local tax authorities are ”completely baffled” by this new 9810 code and do not know how to review it.Most sellers currently shipping via 9810 are actually shipping viaTax-Free, rather than a tax refund.Very few people have actually managed to get their tax refunds processed successfully.

Dimension 3: Documents Required for a Tax Refund

0110

Commercial contracts, packing lists, bills of lading, and special input VAT invoices—standard foreign trade documents with a clear process.

9810

In the absence of a traditional export contract, you’ll need to provide alternative documents such as overseas warehouse booking slips, proof of warehouse ownership, and warehouse lease agreements. Tax officials may also ask to see yourTransaction Orders in the Store BackendTo verify the authenticity of the transaction. The documentation is more fragmented, and the review is more thorough.

Dimension 4: Methods of Foreign Exchange Receipts

0110

needFull Collection of Foreign Exchange

9810/9610/9710

AllowForeign Exchange Receipts Shortfall(Net amount after commission deduction)

Dimension 5: Policy Subsidies

Take Shenzhen as an example: currently, routes 9610, 9710, and 9810 qualify for government subsidies, while route 0110 does not. If you’re in Shenzhen or Guangzhou, taking route 9810 allows you to receive a certain subsidy, which is a tangible cost advantage.

Dimension 6: Multi-store Compatibility (Most Critical)

The Amazon platform requires a ”one company, one store” policy. To open multiple stores and capture more traffic, sellers operate anywhere from a dozen to over a hundred stores under their companies.

Go to 0110:

Merchandise from all stores is consolidated at1 export company...one customs declaration and one tax refund. Simple, efficient, and low-cost.

Take Route 9810:

In theory, the rule is: ”Whoever sets up operations, exports, and claims the tax refund.”If you haveA company with 50 stores, which, in theory, would require 50 companies to each file customs declarations and apply for tax refunds independently, as well as maintain 50 separate sets of financial records.For sellers, this represents a huge administrative and labor cost; for the tax authorities, conducting 50 on-site inspections and reviewing 50 tax refund applications for the same company is also an unbearable burden.

That’s why cross-border sellers in categories 90% and above still choose 0110—it’s not that they don’t want to use 9810, it’s that they can’t.

🎁 Compliance Assessment · Limited to sellers with annual sales of 10 million or more

If your company's annual sales exceed 10 million, scan the QR code to add Qicaiying's online customer service.(Micro-signal: jxhqcy890 / Mobile: 16625410105), contact a finance and tax advisor to schedule a free 30-minute one-on-one compliance assessment.

Based on the number of stores you have, your business model, your purchasing habits, and the city where you’re located, we’ll help you sort through the following:

1. Are there any risk factors associated with your current customs clearance method?

2. Which route is better for you: 0110 or 9810?

3. If a transition is necessary, what are the steps involved, and what will it cost?

⏰ Limited to 3 spots per day; first come, first served

03 Who is 0110 suitable for among cross-border sellers?

✅ Suitable for sellers in category 0110

1. Sellers using the store cluster model (multiple stores, multiple platforms)

If you operate multiple stores, you need to mitigate the risk of having your stores suspended due to platform-related issues. The 0110+ Hong Kong company consolidation model allows you to file customs declarations and claim tax refunds just once, minimizing your management costs.

2. Medium-to-large sellers with annual sales of over 10 million

When business volume is high, tax refunds represent a significant source of revenue. The 0110 tax refund process is the most well-established, offers the fastest payment processing, and ensures the highest efficiency in cash recovery. Listed companies like Anker, Saisi, and Greenconn all use the 0110 process—not because they don’t understand the 9810 process, but because they’ve done the math.

3. Sellers from whom the purchasing party can obtain input tax invoices

For the 0110 tax refund, you must provide special VAT input invoices. If your upstream supplier can issue invoices (or if you’re willing to pay a higher tax rate to obtain them), the 0110 tax refund process will proceed without any issues.

4. Sellers with plans for financing or an IPO

Under the 0110 consolidation model, the equity structure of the parent company is clear, and investors can directly acquire shares in the core export company. Employee stock ownership, external financing, and IPO structures are all easy to implement. Without a single core parent company, your company will be a disorganized mess with no capital value.

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❌ Not suitable for 0110 sellers

1. Small sellers whose buyers are unable to obtain invoices

0110: You need input invoices to claim a tax refund; if you can’t obtain them, you won’t be able to claim the refund. If your annual sales are less than 5 million and all your upstream suppliers are small-scale vendors who don’t issue invoices, it’s more practical to use Form 1039 for tax-exempt status or have your Hong Kong company purchase directly.

2. Sellers of small packages shipped exclusively via direct mail

0110 is suitable for large-volume exports. If you’re shipping small packages directly to consumers one by one, you should use the 9610 tariff code.

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03 Which cross-border sellers is 9810 suitable for?

✅ Suitable for 9810 sellers

1. Single-store premium brand sellers

With only 1–3 stores, we focus on a premium brand strategy, so there’s no need to worry about store closures due to affiliate restrictions. Each store handles customs clearance and tax refunds independently, keeping costs under control.

2. Large sellers supported by robust ERP systems

”9810 Tax Refund Requirement: ”Sales Recalculation'—You must accurately track the sales of each SKU from the overseas warehouse and adjust for over- or under-refunds. If you have hundreds or thousands of SKUs, it’s simply impossible to manage without a robust ERP system."

3. Sellers whose local tax office has successfully processed their 9810 tax refunds

There are significant differences in how familiar tax authorities in different regions are with Form 9810. Tax authorities in cross-border e-commerce hubs like Shenzhen are relatively familiar with it, but many local tax authorities are still figuring it out. If your local tax authority has already approved a tax refund using Form 9810, you can give it a try.

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❌ Not suitable for 9810 sellers

1. Sellers using the store cluster model (Focus)

As mentioned earlier, having 50 store companies operate under the 9810 system means 50 separate customs declarations, tax refund processes, and accounting systems. Management costs skyrocket, the finance team becomes overwhelmed, and funds are scattered across 50 accounts, making it impossible to allocate them effectively.This isn't compliance—it's suicide.

2. Sellers with understaffed finance teams

Regulation 9810 requires each store to have its own corporate bank account, maintain separate accounting records, file taxes independently, and keep complete supporting documents and ledgers. If your finance team consists of only three or five people, they simply won’t be able to handle the accounting workload for dozens of companies.

3. Sellers whose 9810 tax refund applications were not approved by their local tax bureau

There’s no point in filing a declaration for items the tax authority won’t review. First, contact your local tax office to confirm whether they accept Form 9810 and whether the tax refund process will go smoothly before making a decision. If you file a declaration blindly and the refund gets held up, your money will be tied up—and the cost will outweigh the benefit.

4. Sellers Seeking Centralized Fund Management

Under the 9810 model, payments from the platform go directly into the bank accounts of each store’s operating company. If a business owner wants to invest 5 million in a new project, they must ”raise funds” one by one from dozens of store companies, going through complex internal loan or dividend distribution processes. This results in extremely low capital utilization efficiency.

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The conclusion is straightforward:

If your annual sales exceed 10 million and you operate multiple stores using a store cluster model—0110+ Consolidation Through a Hong Kong Company Is Your Best SolutionThe

If you’re a single-store, boutique brand seller with a robust ERP system and have successfully processed Form 9810 with your local tax authority—You can try 9810.

If you're somewhere in between—that's fine.“A Two-Pronged Approach”(math.) genusHigh-margin, large stores use the 9810 tax refund code, while SKUs for bulk inventory are grouped under 0110,Regulatory authorities have not stipulated that companies must use only one method of customs declaration.

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04 Sellers on Route 0110 Must Do These 3 Things

If, after reading this, you decide to take Route 0110 (which is the most likely choice), you must do the following three things:

1. Hong Kong companies cannot merely serve as ”funds transfer hubs.”

The tax authorities have never focused on customs declaration codes; rather, they focus on three things: whether the business transactions are genuine, whether income is reported accurately, and whether taxes are paid in full.

Using the ”0110” structure to set up a Hong Kong company—are all your revenues fully reflected in the Hong Kong company’s books? Does the pricing of transactions with your mainland company hold up to scrutiny? If the Hong Kong company is merely a “shell,” no taxes are paid in either the mainland or Hong Kong—That is the real risk.The

2. The issue of zero-reporting by retail businesses must be resolved.

Once Document No. 15 takes effect, platforms such as Amazon will report sales data from storefront companies to the tax authorities. Is your storefront company still filing zero-revenue returns? If the system detects a significant discrepancy between the platform data and your tax filings, you’ll receive a text message from the tax authorities.

Saiwei 2.0 Model(Overseas Procurement and Overseas Sales) was created precisely to address this issue—allowing the retail company to recognize revenue and file tax returns in good faith, while ensuring the business chain is transparent and traceable through the resale of goods via a Hong Kong company. VAT is exempt, and corporate income tax is paid based on actual profits.

3. Communicate with the relevant tax authority in advance

There are significant differences in how tax authorities in different regions interpret the 0110 aggregation model.Cross-border e-commerce hubs such as Shenzhen and Guangzhou are relatively well-known, but the definitions are not entirely consistent.Before filing customs declarations, contact the local tax authority in advance to discuss the following: Do they accept the pooling method? What documents need to be prepared? Are there any special requirements?

The fundamental purpose of compliance is not ”zero risk,” but rather ”manageable risk.”

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05 It's not that you can't go to 9810, but you should think carefully about three things first.

If you're seriously considering the 9810, ask yourself these three ”tough questions” first:

Question 1: Will you get your money back safely?

Under the 9810 model, payments from the platform go directly into the corporate accounts of each store. Most of your stores are held in the names of others, aren’t they? With millions or tens of millions sitting in accounts under someone else’s name, what will you do if a dispute arises, the funds are frozen, or the account holder disappears?

Question 2: How are funds allocated? How are profits consolidated?

Can the owner access the funds scattered across various stores? If you want to withdraw funds from dozens of store companies to make an investment, you’ll need to go through complex internal loan or dividend distribution processes. Since you aren’t the shareholder of each store company (the shareholders are nominees), you’ll also have to pay 20% in individual income tax on behalf of the nominees when dividends are distributed.You can't control the ”shell,” and you won't get any money.

Question 3: When it comes to future financing, who would you like to be the lead investor?

Who should investors invest in? Should they invest in 100 independent store companies? Without a single core parent company, your business will forever remain a loose collection of disparate parts, with no capital value.

If you can't answer these three questions, don't rush to switch to 9810.

Sellers with annual sales of 10 million: Don’t base your compliance decisions on ”hearsay.”

Ultimately, the choice between 0110 and 9810 isn’t a matter of ”who’s right and who’s wrong,” but rather a matter of ”which one is a better fit for your business.”

Code is static, but business is dynamic. The core of compliance has never been the code itself, but rather ensuring that customs declaration methods align seamlessly with business scenarios, building an authentic, complete, and traceable chain of business evidence, and ultimately ensuring that profits are fully taxed under the appropriate entity.

If your annual sales are10 million or more, operating multiple stores,You're trying to decide whether to take route 0110 or 9810—or maybe you've already chosen a route but aren't sure if it's the right one—That's exactly what we're good at.

Here's what we do for you:

▸ Based on your business scale, number of stores, procurement model, and cash flow, we’ll provide recommendations on the customs clearance method that best suits your needs.

▸ If the 0110 + Hong Kong company structure is right for you, we’ll help you set up a comprehensive compliance system based on the SAIWEI model.

▸ If you have a need for 9810 tax-exemption filing in your area (Shenzhen/Guangzhou/Foshan/Dongguan), we offer professional consulting services.

▸ Identify historical tax risks and develop a systematic compliance transformation plan

We're not giving you a standard answer; instead, we're helping you find the answer that works best for your company.

For sellers with annual sales exceeding 10 million, the most important thing you need to do right now isn’t ”choosing which code to use,” but rather determining your current actual risk level before deciding on your next steps.

🎁 Compliance Assessment · Limited to sellers with annual sales of 10 million or more

If your company's annual sales exceed 10 million, scan the QR code to add Qicaiying's online customer service.(Micro-signal: jxhqcy890 / Mobile: 16625410105), contact a finance and tax advisor to schedule a free 30-minute one-on-one compliance assessment.

Based on the number of stores you have, your business model, your purchasing habits, and the city where you’re located, we’ll help you sort through the following:

1. Are there any risk factors associated with your current customs clearance method?

2. Which route is better for you: 0110 or 9810?

3. If a transition is necessary, what are the steps involved, and what will it cost?

⏰ Limited to 3 spots per day; first come, first served