In 2026, one of the policy topics of greatest concern to cross-border sellers is just how much faster the “tax refund upon departure” for 9810 overseas warehouses will actually be. The answer is a figure that will excite all sellers: once goods have been cleared for export, sellers can pre-file for a tax refund immediately. The time it takes for refunds to be credited has been reduced by more than 40% compared to the past, significantly improving cash flow efficiency.

However, this “speed” comes with certain conditions. The compliance requirements, filing thresholds, and tax accounting logic for the 9810 overseas warehouse model are far more complex than those for the standard 9610 model. If companies continue to account for these transactions based on “estimated profits,” “net cash withdrawals,” or “platform revenue,” they will not only fail to enjoy the convenience of “tax refund upon departure,” but may also be rejected by the tax refund review system due to discrepancies between recorded and actual figures.

Duty-free returns, overseas warehouse registration, online verification of foreign exchange receipts, and the integration of tax and foreign exchange data—a series of supporting policies related to the 9810 procedure will be implemented simultaneously in 2026, forming a complete closed-loop system for cross-border sellers to recover their funds. Only by understanding this closed-loop system can sellers truly reap the benefits of these policies.

Qicaiying Group specializes in providing domestic and international company registration services in Shenzhen, Guangzhou, Shanghai, Beijing, Hangzhou, Hong Kong, the United States, Japan, South Korea, Southeast Asia, Singapore, the British Virgin Islands (BVI), the Cayman Islands, and other locations, as well as annual review and audit, bookkeeping and tax filing, tax compliance, information updates, bank account opening, ODI filing, FDI filing, and other corporate services; Hong Kong residency application, renewal, and permanent residency services; Singapore EP application services; and cross-border e-commerce support and agency services. If you have any needs or are interested, please feel free to contact me at any time (Consultation Hotline: 18676749275, add WeChat: Qicaiyingjituan).

I. Just How Much Faster Is the 9810 “Tax Refund Upon Departure” Program? The Logic Behind the System and Key Timelines

The core of the 9810 overseas warehouse model is to move the timing of export tax refund declarations forward from “after the goods are sold” to “after the goods clear customs and leave the country.” Under the traditional 9610 model, sellers must wait until the buyer receives the goods, the platform settles the payment, and foreign exchange proceeds are received before they can formally file for a tax refund; the cash recovery cycle typically takes 3–6 months. Under the 9810 model, sellers can file a preliminary tax refund claim as soon as the goods are cleared through customs and exported, with formal settlement occurring once the foreign exchange proceeds are received.

The specific timeline is as follows:

Step 1: Customs clearance for export. The goods were declared under the 9810 mode and actually left the country; Customs generated the export declaration data and transmitted it to the tax system.

Step 2: Pre-file for a tax refund. Sellers may submit a preliminary tax refund declaration to the competent tax authority once the goods have left the country; the tax system will preliminarily review the refund amount based on the value stated on the customs declaration form.

Step 3: Tax refund is credited to your account. After preliminary review is approved, the tax authorities will transfer the tax refund to the company’s corporate bank account, reducing the overall processing time by more than 40% compared to the traditional model.

Step 4: Verification of Foreign Exchange Receipts. Once the funds are received from the platform, settled on T+14, or received via a third-party payment provider, the seller must submit the foreign exchange receipt data to complete the formal write-off.

It is important to note that “Tax Refund upon Departure” is a provisional tax refund mechanism; formal clearance still requires compliance with the “four-way consistency” principle: the entities listed on the customs declaration, bill of lading, foreign exchange receipt, and income receipt must match, the amounts must correspond, and the sequence of events must be reasonable.

II. Extension of Duty-Free Return Policy: Official Measures to Reduce Trial-and-Error Costs for Overseas Warehouses

In addition to the “Tax Refund on Departure” policy, the tax-exempt return policy—which will continue into 2026—is another significant benefit for sellers. Goods stored in overseas warehouses that need to be returned to China due to slow sales, buyer returns, quality issues, or other reasons may qualify for tax-free return shipping, exempting them from import duties, value-added tax, and consumption tax.

The eligibility requirements for duty-free returns primarily include:

First, the returned goods must be identical to the original exported goods. The product name, specifications, quantity, and value of returned goods must match those on the original export customs declaration form and be supported by a complete logistics history.

Second, the time limit for returning goods. Declarations for returned goods must be filed within the specified time limit from the original export date; if filed late, they will be treated as general trade imports.

Third, standardized accounting procedures. The sales revenue, tax refunds, and cost accounting related to returned goods must be clearly documented and verifiable; companies are required to maintain a ledger for returned goods.

The practical value of duty-free returns lies in the fact that the government has reduced the cost of trial-and-error for overseas warehouses, allowing sellers to adopt bolder product selection strategies when setting up overseas warehouses. In the event of slow-moving inventory or returns, sellers can return the goods in compliance with regulations rather than clearing them out at low prices or destroying them.

III. Overseas Warehouse Registration and Subsidies from the Hunan China-Africa Economic and Trade Pilot Zone

The first step toward compliance for Overseas Warehouse 9810 is “registration.” Overseas warehouses that have not completed customs registration are not eligible for tax refunds upon export or tax exemptions for returned goods. Required registration documents include: domestic business credentials, proof of ownership or right to use the overseas warehouse, warehouse floor plans and storage capacity, and the overseas warehouse operating agreement.

Both the national and local governments offer subsidy policies for the construction of overseas warehouses. The support provided by the Hunan Pilot Zone for In-Depth Economic and Trade Cooperation with Africa is particularly notable:

Subsidies for Setting Up Your Own Overseas Warehouses: 30% of the actual investment amount, with a cap of 5 million yuan per country.

Subsidies for Leasing Overseas Warehouses: 50% of venue rental costs, capped at 1 million yuan per country.

Operating Subsidies: The operating expense subsidy for the first year is 50%, capped at 500,000 yuan; for the second year, it is 30%.

Credit Insurance Subsidies: 50% of the premium, capped at 2 million yuan per year.

Annual award and subsidy cap per company: 20 million yuan.

In addition, there are supporting policies such as the China-Africa Economic and Trade Deep Cooperation Service Fund (with a quota of 360 billion yuan), the 9810 tax refund upon departure program (advance refund: 70%-90%), and the extension of tax-free returns for returned goods. When it comes to cross-border trade with Africa, the key policy resources are in Hunan, not Yunnan.

For the 9810 overseas warehouse layout, Qicaiying provides end-to-end services covering “e-commerce compliance accounting, export tax rebates, overseas warehouse registration, and overseas company incorporation”: Overseas warehouse registration guidance, optimization of the 9810 customs clearance process, preliminary tax refund declarations and formal settlement, applications for tax-exempt return shipments, establishment of overseas entities (Hong Kong, BVI, Singapore, South Africa, etc.), and compliant repatriation of cross-border funds. Qicaiying Group specializes in providing domestic and international company registration services in Shenzhen, Guangzhou, Shanghai, Beijing, Hangzhou, Hong Kong, the U.S., Japan, South Korea, Southeast Asia, Singapore, the BVI, the Cayman Islands, and other locations, as well as corporate annual review and audit, bookkeeping and tax filing, tax compliance, information changes, bank account opening, ODI and FDI filings, and other corporate services; Hong Kong residency application, renewal, and permanent residency services; Singapore Employment Pass (EP) application services; cross-border e-commerce mentoring and managed operations; and other one-stop services. If you have any needs or are interested, please feel free to contact me at any time (Consultation Hotline: 18676749275, add WeChat: Qicaiyingjituan).

IV. Online Verification of Foreign Exchange Receipts and Integration of Tax and Foreign Exchange Data

Another key aspect of the "Tax Refund upon Departure" policy under 9810 is the integration of foreign exchange receipt verification with tax and foreign exchange data. By 2026, the tax system will achieve data sharing with the State Administration of Foreign Exchange (SAFE) and banks; the amounts, dates, and entities reported by enterprises for foreign exchange receipts must match the data reported to SAFE.

First, the foreign exchange collection period is standardized. The deadline for receiving export proceeds is uniformly set for April 30 of the following year; goods for which proceeds have not been received by that date must be treated as domestic sales and subject to taxation.

Second, matching of foreign exchange recipients. The entity receiving the foreign exchange must be the lawful payee under the export contract and must be the same as the entity filing the tax refund claim.

Third, matching the amount of foreign exchange receipts. If the discrepancy between the actual amount of foreign exchange received and the amount declared on the customs declaration or the amount claimed for a tax refund exceeds a reasonable range, a written explanation must be provided.

In the past, some sellers have “inflated” their foreign exchange receipts through third-party payment collection, underground money transfer services, and fictitious foreign exchange receipts; with the data integration set to take effect in 2026, these practices will be impossible to conceal.

V. Three-Step Process for Recovering Funds from Overseas Warehouses: Filing, Declaration, and Archiving

9810: The compliance procedures for cash recovery from overseas warehouses can be summarized in three steps.

Step 1: Registration and File Creation. Complete customs registration for the overseas warehouse and establish a inventory ledger for the overseas warehouse: ensure a one-to-one correspondence between the inventory list, customs declaration forms, bills of lading, contracts, and payment records.

Step 2: Daily Reporting and Document Filing. Compile platform sales data, foreign exchange receipts, and tax refund data on a monthly basis to ensure consistency among the four sets of data: customs declarations, foreign exchange receipts, tax filings, and tax refunds. When submitting a preliminary tax refund application, attach all supporting documents, including customs declarations, bills of lading, contracts, invoices, payment vouchers, and foreign exchange receipt vouchers.

Step 3: Annual Write-offs and Risk Review. Complete the formal write-off of all 9810 transactions before the annual tax settlement and finalization, and resolve the status of goods for which payment has not been received, that have been returned, or that have been sold; conduct regular risk reviews of tax refund data to prevent rejections by the tax refund review system due to discrepancies between book records and actual inventory.

The “Tax Refund upon Departure” policy (9810) offers significant benefits, but these benefits are reserved for those who are prepared. Qicaiying Group specializes in providing domestic and international company registration services in Shenzhen, Guangzhou, Shanghai, Beijing, Hangzhou, Hong Kong, the United States, Japan, South Korea, Southeast Asia, Singapore, the British Virgin Islands (BVI), the Cayman Islands, and other locations, as well as services such as annual company audits, bookkeeping and tax filing, tax compliance, business registration updates, bank account openings, ODI and FDI filings, and other corporate services; Hong Kong residency applications, renewals, and permanent residency services; Singapore Employment Pass (EP) application services; and cross-border e-commerce support and management services. If you have any needs or are interested, please feel free to contact me at any time (Consultation Hotline: 18676749275, add WeChat: Qicaiyingjituan).

In 2026, the competition in cross-border e-commerce will no longer be about “who can seize the benefits,” but rather “who can consistently capitalize on them.” By ensuring proper registration, maintaining accurate financial records, and processing tax refunds in a timely manner, 9810 overseas warehouses can truly become a source of revenue for sellers rather than a compliance minefield.