When it comes to customs classification codes for cross-border e-commerce exports, selecting even one incorrect digit can throw off the entire tax refund process. 9710 and 9810 are the codes most commonly confused.

What exactly do these two lines of code do?

9710 — Cross-border E-commerce B2B Direct Exports: After a domestic enterprise concludes a transaction with an overseas enterprise through a cross-border e-commerce platform, it exports the goods directly to the overseas enterprise via cross-border logistics. The key feature isB2B, direct exports, corporate buyersThe

9810 — Cross-border E-commerce Export Overseas Warehouses: Domestic companies first ship goods to overseas warehouses; after a transaction is completed through a cross-border e-commerce platform, the goods are then delivered from the overseas warehouse to the international buyer. The key feature isShip goods overseas first, finalize the sale later, and fulfill orders from an overseas warehouseThe

The difference in a nutshell:When inspecting the goods, should they be sold to the customer first and then exported, or should they be exported first, stored in the warehouse, and then sold?

Why Does This Choice Affect My Tax Refund?

The signature policy under the 9810 model is ”tax refund upon departure”—export tax refunds can be claimed as soon as goods are cleared for export, without having to wait for actual sales to be completed at overseas warehouses and then settle accounts based on actual sales figures. This provides a substantial benefit in terms of reducing capital tied up.

The 9710 model follows the standard export tax refund process, where claims are filed in accordance with current regulations based on documents such as customs declarations and input invoices. The timing of tax refunds depends on the speed of customs clearance and document collection, rather than the pace of inventory preparation.

It is important to note that,The prerequisite for a tax refund is the existence of compliant input invoices and actual export shipments.. The practice of ”purchasing without invoices,” which is widespread in the cross-border e-commerce industry, is not automatically exempt under either of these codes. While there was once a transitional arrangement for assessed taxation under code 9610, the shift from assessed taxation to book-based taxation has been clearly established, and the era of maintaining high gross margins through tax exemptions based on purchases without invoices is coming to an end.

Three Discrepancies Between the Customs Declarant and the Data

In practice, the problems that arise are often not caused by the code itself, but rather by discrepancies between three sets of data:

Issue 1: The customs declarant and the store owner are not the same entity. Having Company A handle customs clearance, Company B receive foreign exchange, and Company C operate the store is the most common example of a failure to achieve the ”integration of the four flows.” The sales flow, logistics flow, customs clearance flow, and capital flow must all point to the same commercial substance.

Issue 2: The declared value does not match the actual transaction amount. 9810: Customs clearance must be completed before sales. When clearing customs, goods are declared at cost or an estimated value, but the actual selling price on the platform is often higher. How this difference is reflected in the books and whether VAT must be reported at the place of sale must be planned in advance.

Issue 3: No foreign exchange receipts from exports or irregularities in the foreign exchange receipt process. Platform-automated withholding and remittance, consolidation by third-party payment collection tools, and deductions for exchange rate differences and service fees can all result in the amount of foreign exchange received being less than the amount declared on the customs declaration; therefore, a complete chain of documentation for these deductions must be prepared.

Income Tax and Taxation at the Place of Sale Under the Overseas Warehouse Model

Once goods enter an overseas warehouse, they may constitute, in the market where they are sold,Permanent Inventory Facilitiesor trigger local VAT/sales tax registration requirements. This means that Form 9810 is not just about tax refunds in China, but also raises issues regarding tax status in the country of sale:

• In the United States, the thresholds that may trigger a state’s sales tax nexus
• In the EU, this may trigger the obligation to register for the IOSS or for VAT in individual countries.
• In Mexico, shipments from local warehouses affect the RFC tax ID and the applicable tax rate withheld by the platform.
• In South Africa, stocking local warehouses is directly related to CE-01 filing and non-resident VAT registration.

Therefore.Before deciding to use Form 9810, you should first complete an assessment of your tax status in the country of sale.. Otherwise, even if you receive the tax refund from China, the amount of back taxes you’ll have to pay in the country where the sales took place might be even higher.

A Decision-Making Framework

• Order-driven, with overseas clients, and large order amounts → 9710 fits better
• Inventory-driven, focused on end consumers, and prioritizing local delivery speed → 9810 is a better fit
• Coexistence of Two Types of Business → Use different codes for each case, but ensure that the data is distinguishable and traceable in both the accounting system and the customs declaration data.

According to industry sources, the requirements for document retention and post-transaction audits for cross-border e-commerce exports will continue to be strengthened in 2026. There are specific filing deadlines for export tax refund (or exemption) declarations; failure to file by the deadline may result in the transaction being treated as a domestic sale. Relevant documents must be retained for inspection in accordance with regulations, and the retention period is relatively long; it is recommended to design an archiving structure at the ERP level in advance.

Qicaiying offers services including the design of cross-border e-commerce export structures, the review of customs clearance and tax refund compliance, and assessments of tax ID numbers and the current status of main entities in target markets.