Sister Wang, who runs an Amazon business in Guangzhou, has annual export sales of over 20 million. She had always used the general trade 0110 customs declaration, which came with high tax burdens and slow tax refunds. Later, after hearing from a colleague that the 9810 method offered “tax refunds upon departure,” she was intrigued, but was worried the process might be too complicated for her to handle.

Regulatory codes for cross-border exports are essentially different “customs clearance + tax refund” packages. Choosing the right one can make a world of difference in terms of cash flow and tax burden.

01

Four Common Codes Explained in One Sentence

9610: Cross-border e-commerce B2C small-package exports, suitable for Amazon Fulfillment by Seller and direct shipping from independent websites. Key features include release based on a packing list and consolidated declarations; tax exemptions are available for shipments without invoices.

9710: Cross-border e-commerce B2B direct exports, where companies conduct transactions with foreign enterprises through cross-border e-commerce platforms. These transactions are governed by general trade regulations and are eligible for export tax rebates.

9810: In cross-border e-commerce export models using overseas warehouses, goods are first shipped to overseas warehouses and then dispatched from there once sold. The biggest draw is “tax refund upon departure,” which means you don’t have to wait for the actual sale to take place.

0110: Traditional general trade—the most common method, but also the most cumbersome in terms of paperwork and the one with the longest tax refund processing time.

02

Just how much of a difference is there in the tax burden?

9610 Tax-Free Without a Receipt:If you are a small seller and cannot obtain input invoices, you can use the 9610 code to opt for “exemption without refund.” This means the VAT is exempt, but no tax refund is available. This option is suitable for small-package businesses with low profit margins and few input invoices.

9610 Tax Refund with Receipt:If you have input invoices, the tax burden can be reduced significantly by applying the taxable income rate or the assessed taxation method. However, implementation guidelines vary by region, so it is important to confirm this in advance.

9810 Advance Tax Refund:Once the goods have left the country, you can file Form 70% to claim a refund of input tax; the write-off can be completed after the overseas warehouse has actually made the sales. This is a major benefit for cash flow, especially for sellers with large inventories.

9710 Treated as General Trade:The refund is processed according to the 13% refund rate, and it applies to the VAT already paid during the procurement process. This is contingent upon the supplier being able to issue a special VAT invoice and the customs declaration documents being complete.

A simple comparison: For an export with the same value of 1 million, under HS code 9810, the input tax credit (70%) may be refunded upon departure; under HS code 0110, the refund must wait until the sale is completed and all documentation is in order; and under HS code 9610, no refund is issued without an invoice, but the tax is exempt.

03

9810: Not everyone can do it

9810 It sounds appealing, but the barriers to entry are high. First, you must have a warehouse overseas—it can be a self-owned warehouse, a third-party warehouse, or a platform-managed warehouse. Second, you must have the necessary cross-border e-commerce business registration. Third, after exporting the goods, you must complete sales and clear the customs within the specified timeframe; otherwise, you may be required to repay any tax refunds received.

In addition, 9810 imposes strict requirements on financial accounting. The five documentation streams—input invoices, customs declarations, overseas warehouse receipt forms, sales orders, and payment records—must all correspond. If even one link is missing, the tax refund process may be held up.

Many sellers run into problems not because there’s anything wrong with the business model itself, but because they failed to set up their financial systems in advance. They assumed that simply changing their supervision code would allow them to claim a tax refund, but they ended up with incomplete documentation, couldn’t get the refund, and had to pay late payment penalties.

04

How to Choose

Small sellers, primarily direct shipping, with few input invoices: Give priority to the 9610 tax-exempt option without invoices.

If you have stable suppliers, can obtain special VAT invoices, and have a high volume of B2B orders: 9710 is a better fit, as tax refunds are more reliable.

Stocking overseas warehouses and facing significant cash flow pressures: The 9810 advance tax refund can significantly improve cash flow, but it requires effective financial management and overseas warehouse management to support it.

Large scale, numerous SKUs, and strong suppliers: You can use a combination of 9610, 9710, and 9810, segmented by business line.

In a nutshell: When choosing a regulatory code, first consider the nature of the business, then assess invoicing capabilities, and finally determine whether the financial systems can keep up.

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