01 9610 Model: Small-Value Cross-Border Direct Mail (Policy Continuation + Efficiency Improvements)

▪ Target Sellers: Small and medium-sized sellers on platforms such as AliExpress, TikTok Shop, and Shopee, as well as self-fulfilling merchants with independent websites, specializing in lightweight, small items such as 3C accessories, apparel, and beauty products.

▪ Key Features: Optimization of the “list-based release and consolidated declaration” mechanism; by 2025, automatic data integration between customs and tax systems will be achieved, and the tax refund declaration cycle will be shortened to 7 business days; support for expedited clearance of orders with a value of 5,000 yuan or less per shipment.

▪ Restrictions and Precautions: If the value of a single shipment exceeds 5,000 yuan, it must be declared under general trade; no additional electronic payment receipt information is required for tax refunds, but supporting documentation—such as a complete logistics tracking record and order screenshots—must be provided; data inconsistencies will affect the tax refund review; Cross-customs district returns for cross-border e-commerce retail exports are supported; returned goods must be sent to a designated customs supervision facility.

02 9710 Model: Cross-border E-commerce B2B Direct Export (Strengthened Regulation)

▪ Target Sellers: Merchants on B2B platforms such as Alibaba International and Made-in-China, as well as traditional foreign trade companies undergoing transformation, who export bulk goods directly to overseas companies.

▪ Key Features: Essentially “online general trade”; as of 2025, a new requirement for “electronic contract filing” has been introduced, requiring electronic contracts to be signed and uploaded for filing via a platform approved by customs; eligible for the same tax refund policies as general trade; supports nationwide integrated customs clearance; and allows for flexible selection of the port of shipment.

▪ Risk Notice: Data related to orders, logistics, and funds must fully match. False transactions and data tampering will result in administrative penalties from customs and may affect the company’s credit rating.

03 9810 Model: Cross-border E-commerce Export to Overseas Warehouses (Benefits of the New Tax Rebate Policy)

▪ Target Sellers: Amazon FBA sellers and companies operating their own overseas warehouses, focusing on high-volume, fast-moving SKUs such as home goods, electronics, and outdoor gear.

▪ Key Features: The “Tax Refund Upon Departure” policy will be fully implemented in 2025; tax refunds can be applied for as soon as goods arrive at overseas warehouses and clear customs, without having to wait for final sales. The platform supports a “bulk stocking + overseas distribution” model, significantly improving shipping efficiency.

▪ Challenges and Solutions: There is significant upfront capital pressure, which can be alleviated by using supply chain finance tools to ease cash flow constraints; there is no need to register for overseas warehouse operations, but electronic data for warehouse booking orders must be transmitted to customs, and inventory data must be reported periodically.

04 1210 Model: Bonded E-commerce Model (Higher Entry Barriers)

▪ Target Sellers: Medium- to large-sized enterprises with strong financial resources that operate under the “bonded inventory” model, such as merchants on Tmall Global and JD Worldwide.

▪ Key Features: Tax refunds can be applied for as soon as a full shipment enters the comprehensive bonded zone; after consumers place orders, goods are shipped directly from the bonded zone, with delivery times comparable to those of domestic e-commerce platforms; in 2025, a new requirement for “real-time monitoring of bonded zone inventory” was introduced, requiring inventory data to be synchronized with the customs system.

▪ Entry Requirements: Must obtain eligibility to operate in the bonded zone, with a registered capital of no less than 5 million yuan; stocking inventory in bulk places high demands on cash flow, making this option suitable for brand sellers with a high concentration of SKUs.

05 0110 Model: Traditional General Trade (Stable Policies + Optimized Tax Rebates)

▪ Target Sellers: Companies transitioning from traditional foreign trade that export high-volume, high-value, branded products (such as machinery and equipment, and high-end electronics).

▪ Key Features: The most stable policy and the highest tax refund rates (10%–13%); improved tax refund processing efficiency in 2025, with the average time for tax refunds to be credited reduced to 15 business days; highly versatile, suitable for a wide range of export scenarios.

▪ Key Requirements: Complete documentation, including contracts, invoices, and packing lists, must be provided, and all information must strictly match the customs declaration form; input invoices must be genuine and valid, and the issuance of fraudulent invoices is strictly prohibited.

06 1039 Mode: Market Procurement Trade (Quota Increase + Scope Expansion)

▪ Applicable Sellers: Small and medium-sized merchants without import/export rights, with fragmented procurement channels, and who have difficulty obtaining input tax invoices—such as merchants at the Yiwu Small Commodities City and the Guangzhou Foreign Trade City—who are explicitly required to “complete registration on the Market Procurement Trade Network Information Platform.”

▪ Key Features: The maximum value per shipment will be raised from $150,000 to $200,000 in 2025; Exempt from value-added tax (VAT), with no requirement to issue VAT invoices, and eligible for the 0.4%–1% fixed-rate taxation policy; a new “online procurement filing” feature has been added to streamline the filing process.

▪ Key Advantages: Specifically addresses the challenge of “invoice-free exports” for small, medium, and micro businesses, with the lowest compliance costs and a streamlined process.

07 New: 9610B Model (Cross-border E-commerce B2B Direct Mail, to be piloted and promoted in 2025)

▪ Eligible Sellers: Sellers who export goods to small-volume overseas buyers through independent websites or B2B platforms, with order values ranging from 5,000 yuan to 500,000 yuan.

▪ Key Features: Combining the convenient customs clearance process of the 9610 procedure with the B2B attributes of the 9710 procedure, this system supports “itemized declaration + consolidated tax refund”; there is no need to provide a complete foreign trade contract—only order screenshots and shipping documents are required.

▪ Pilot Scope: The pilot program will first be launched in 2025 in cross-border e-commerce comprehensive pilot zones such as Guangdong, Zhejiang, and Jiangsu, and will subsequently be rolled out nationwide.

Customized Compliance Solutions for Different Types of Sellers (2025 Optimized Edition)

● New sellers (annual sales under 1 million yuan)

▪ Key Objectives: Minimize compliance costs, get up and running quickly, and mitigate initial tax risks.

▪ Recommended Solution: 1039 Market Procurement Trade (the preferred option for invoice-free exports) + 9610 Small-Value Direct Mail (for small-batch orders).

▪ Key Implementation Points:

By completing the filing process through market procurement trade clusters (such as Yiwu and Guangzhou), there is no need to apply for import and export rights independently.

Select a compliant market procurement trade agent to ensure that all documentation is properly filed.

Avoid declaring amounts exceeding the limit (single invoice ≤ $200,000); otherwise, the transaction must be converted to general trade.

● Small and medium-sized sellers (annual sales of 1 million – 5 million yuan)

▪ Key Objectives: Balance compliance costs with tax refund benefits, streamline operational processes, and support business expansion.

▪ Recommended Plan: 1039 Market Procurement Trade (Main Model) + 9610B Model (supplementary for small B orders).

▪ Advantages:

Orders without invoices are exported in compliance with Mode 1039 to reduce the tax burden

Xiao B’s orders benefit from expedited customs clearance and tax refunds through the 9610B model to boost profits

No need to invest heavily in building a compliance system; ideal for rapid expansion phases

● Medium- to large-sized sellers (annual sales of 5 million yuan or more)

▪ Key Objectives: Maximize tax refund benefits, ensure brand compliance, and support multi-platform and multi-warehouse operations.

▪ Recommended Solution: 0110 General Trade (branded products, high-value products) + 9810 Overseas Warehouse Model (mass-market products).

▪ Key Implementation Points:

Apply for general taxpayer status, standardize the management of input invoices, and ensure a smooth tax refund process

Overseas warehouses must complete customs registration, submit inventory and sales data on a regular basis, and are eligible for “tax refunds upon departure.”

Establish a management system that integrates the “orders, logistics, funds, and invoices” into a unified framework to prepare for tax audits

● Multi-platform + multi-category sellers (annual sales of 10 million yuan or more)

▪ Key Objectives: Isolate risks across business lines, implement granular compliance management, and optimize the overall tax burden.

▪ Recommended approach: A “separation of models + independent accounting + data isolation” framework.

▪ Practical Examples:

Brand flagship stores and high-value products (such as 3C electronics and high-end cosmetics): Use the 0110 general trade code to maximize tax refunds.

Unbranded bulk goods and low-value products (such as household goods and accessories): Use the 1039 Market Procurement Trade scheme to reduce the tax burden

Products Stocked in Overseas Warehouses: Follow the 9810 Model to Take Advantage of the New Tax Rebate Policy

Xiao B Wholesale Orders: Use the 9610B model to improve customs clearance efficiency

Risk Isolation: Separate accounting accounts are established for different business lines, and logistics documents and customs declaration data are strictly separated to prevent violations in a single business line from affecting overall operations.

● Cross-border brand sellers (global expansion)

▪ Key Objectives: Global tax compliance, avoidance of double taxation, and protection of the brand’s image.

▪ Recommended Solution: 0110 General Trade (Core Markets) + 9810 Overseas Warehouses (Localized Operations) + Cross-Border Tax Planning (Legitimate Tax Avoidance).

▪ Advanced Strategies:

Establish a regional operations center in Hong Kong or Singapore to coordinate global cash flows

Use bilateral tax treaties to claim tax credits and avoid double taxation

Standardize tax reporting for overseas warehouses—such as EU VAT and U.S. sales tax—to avoid local tax penalties

Answers to Frequently Asked Questions on Tax Compliance in 2025

01 Will there be any changes to the criteria for determining small-scale taxpayers and general taxpayers in 2025?

▪ No change: Taxpayers with annual sales of 5 million yuan or less are classified as small-scale taxpayers; those with annual sales exceeding 5 million yuan will be mandatorily classified as general taxpayers.

▪ Additional Note: Small-scale taxpayers may voluntarily apply to become general taxpayers; this is suitable for sellers who need tax refunds or whose business is expanding rapidly.

02 If there are no input invoices, are there any other compliant options besides the 1039 method?

There are two supplementation options:

▪ Select Mode 9610B (Small B Orders); no input invoices are required—only the order and shipping documents need to be provided.

▪ Entrust a qualified comprehensive foreign trade service provider (such as Sinotrans or Huamao Logistics) to act as your export agent, which will provide “invoice-free customs clearance + compliant declaration” services; however, a service fee will apply.

03 Do I need to file a tax return for excess inventory in overseas warehouses?

▪ Domestic Taxation: Since export declarations were completed when the goods left the country, no duplicate domestic taxes are required on excess inventory.

▪ Overseas Taxation: You must comply with local tax regulations. For example, in EU countries, inventory held beyond a certain period may be subject to a warehousing tax, and some U.S. states impose property taxes on long-term excess inventory. It is important to familiarize yourself with local policies in advance.

04 What are the key changes to the export tax rebate policy in 2025?

▪ Improved tax refund efficiency: The processing time for general trade tax refunds has been reduced to 15 business days, and the processing time for tax refunds under the 9810/1210 modes has been reduced to 7–10 business days

▪ Enhanced tax refund audits: Audits will focus on verifying the authenticity of input invoices and the completeness of logistics records; those found to have filed fraudulent tax refund claims will face fines and tax recovery.

▪ New “Fault-Tolerance Mechanism”: Errors in reporting caused by system failures or data transmission delays may be corrected within 30 days, and no penalties will be imposed.

05 Is it still possible to conduct "buy-and-sell" exports? What are the risks?

▪ Not recommended: Once customs and tax systems are integrated in 2025, goods exported via third-party invoicing will be unable to complete compliant declarations, resulting in a disconnect between cash flow and the physical movement of goods, which makes them highly susceptible to being classified as “false exports.”

▪ Consequences of the risk: The company may face back taxes, fines, and a downgrade in its credit rating; relevant accounts may be frozen; and in serious cases, the company may be placed on the “List of Untrustworthy Enterprises,” resulting in restrictions on its cross-border business operations.

Conclusion: Compliance Is a Long-Term Competitive Advantage for Cross-Border E-Commerce

By 2025, global cross-border tax compliance will enter “uncharted waters,” with regulation shifting from “all talk and no action” to “precise and routine.” For sellers, compliance is no longer an extra cost but a core competitive advantage that helps mitigate risks and reap policy benefits—standardized filing procedures ensure you receive tax refunds smoothly, compliant business models help you avoid account freezes, and sound tax planning allows you to optimize your overall tax burden.

Sellers are advised to select the appropriate customs clearance model and compliance solutions based on their business scale, product types, and platform strategy, and to establish a comprehensive compliance system that encompasses “pre-planning, in-process control, and post-event review.” In an era of tax transparency, only by adhering to compliance standards can sellers navigate the global market steadily and achieve long-term sustainable development.

Previous Recommendations

▪ Announcements No. 15 and No. 17 Take Effect: Cross-Border E-Commerce Enters the Era of “See-Through” Compliance—An Analysis of Four Business Models

▪ Tax Challenges and Compliance Guidelines for Cross-Border E-Commerce: From Export Tax Rebates to Overseas Taxation

▪ What Is Phase IV of the Golden Tax System? The Truth About “Data-Driven Taxation” That Cross-Border E-Commerce Sellers Must Know

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