Mr. Chen, a business owner in Dongguan, runs an Amazon home goods business. By the end of 2025, he found himself facing a cash flow crunch—he had a shipment worth 6 million destined for an FBA fulfillment center in the Western U.S. Under normal circumstances, he would have to wait until the products were actually sold overseas to receive a tax refund, which would take at least 3 to 6 months.

In early 2026, he shifted his business model to 9810 (cross-border e-commerce exports via overseas warehouses) and filed for ”tax refund upon departure.” He received an advance tax refund within a week of the goods clearing customs and leaving the country.

He told us, ”In the past, it was ’you only get a refund after you make a sale’; now, it’s ”you get the money as soon as you ship it.’ These two cash flows are a lifeline.”

But he also ran into a snag—it wasn’t until just before the accounting period closed on April 30 of the following year that he discovered some 30% units from that shipment had not been sold, and he would have to repay the difference in the estimated tax refund.

This article breaks down the entire process of ”tax refund upon departure”—from filing the claim to final settlement—step by step.

01

What Exactly Is 9810: Regulatory Codes and Applicable Scenarios

9810 is the customs supervision mode code, with the full name ”Cross-border E-commerce Export to Overseas Warehouses.” The corresponding business activities are:Domestic companies first ship goods to overseas warehouses via cross-border logistics, then complete transactions through cross-border e-commerce platforms, after which the goods are delivered directly from the overseas warehouses to international consumers.The

Compared to 9710 (B2B direct exports), the key difference lies in the business process. Under 9710, the process is ”close the deal first, then ship”; under 9810, it is ”stock the goods first, then close the deal.”

Typical use cases for the 9810:

Amazon FBA bulk shipments to overseas fulfillment centers; sellers using multiple platforms with overseas fulfillment centers (operating on Temu, TikTok Shop, Walmart, etc.); independent e-commerce sites with their own overseas fulfillment centers for inventory preparation.

9810 Scenarios where this does not apply:

9710: Large-volume B2B orders for direct export; retail exports from cross-border e-commerce comprehensive pilot zones (subject to the ”tax-exempt without invoice” policy; not processed under 9810); ”9810-tagged invoice-issuing” transactions that lack actual warehousing and complete sales records.

To process export tax refunds properly, sellers must hold valid input tax documents (such as special VAT invoices). If sellers attempt to claim tax refunds by forcing the use of the 9810 code without input tax invoices, without the goods actually being stored in a warehouse, or without complete sales records, serious problems will arise in the regulatory environment in 2026.

02

Tax Refund Upon Departure: The Biggest Policy Benefit of 2026

The most significant change in the 9810 tax refund system is the implementation of the ”tax refund upon departure, with sales accounted for later” policy.

According to “Announcement No. 3 of 2025 of the State Taxation Administration,” once goods shipped to overseas warehouses under the 9810 procedure have cleared customs for export, export tax refunds (or exemptions) may be claimed based on documents such as the export customs declaration form. This policy was fully implemented in 2026.

Goods Sold:File for and process export tax rebates in accordance with current regulations.

Unsold Goods:Enterprises may choose to apply for advance export tax refunds through the ”Overseas Warehouse Advance Refund” declaration process.

The essence of advance tax refunds is to issue the refund first and then verify it later. Subsequent sales of the goods, inventory changes, returns, and unsold inventory must all be included in the accounting and management process.

9810: The Three-Pronged Policy Dividends:

First layer,Tax Refund Upon Departure. Once goods have cleared customs for export, you can apply for an advance tax refund. For mainstream categories such as 13%, a full refund is available, with funds returned within 3–5 business days—compared to 3–6 months under the traditional model. Guangdong’s “9810” export volume surged 9.8 times year-over-year, exceeding 69.1 billion yuan; in the first four months of 2026, exports under the “9810” category through Shenzhen alone exceeded 74.94 billion yuan.

Second,Eliminate Prior Approval Requirements. The manual pre-approval process for overseas warehouse locations has been fully eliminated, shifting from pre-entry approval to post-event data traceability verification; small and medium-sized sellers can now complete the qualification process within one week.

Third,Extension of Duty-Free Return PolicyFrom January 1, 2026, to December 31, 2027, non-food goods exported under code 9810 that are returned in their original condition within six months are exempt from import duties, value-added tax, and consumption tax. Regarding Amazon’s 10%-20% standard return rate for slow-moving inventory, slow-moving items may be returned, refurbished, and relisted.

03

Practical Guide to Filing: HWC-YT Three-Piece Set

9810: There are three common pitfalls in the filing process; if you miss any one of them, your submission will be rejected by the system.

First: Be sure to check the ”Overseas Warehouse Pre-Return” box on the declaration detail form.

Enter "HWC-YT" as the business type code. This field is the key identifier in the tax system for the 9810 advance tax refund. If this field is left blank or filled in incorrectly, the filing is likely to be rejected outright.

Second: Clearly distinguish between goods that have been sold and those that have not.

The portion that has already been sold is processed through the formal export tax refund declaration; the portion that has not yet been sold is processed through the advance tax refund declaration.

If, under the same customs declaration item number, some goods have been sold and others have not, the company may file separate declarations. If no distinction is made, the system will generally treat all goods as unsold and declare them entirely under the advance tax refund category.

Third: Manufacturing enterprises use independent declaration numbers, while foreign trade enterprises use independent association numbers.

Doing so will keep data on advance tax refunds separate from that on regular export tax refunds, making it easier to review and reconcile the accounts later on and ensuring that things don’t get mixed up during audits or when tracing the source of transactions.

04

The Big Accounting Test: April 30 of the Following Year Is the Deadline

Receiving your preliminary tax refund does not mean that the 9810 tax refund process is complete.

Accounting Cycle: The period begins on the first day of the month following the month in which the tax authorities finalize the export tax refund and ends on April 30 of the following year.

Enterprises must complete the confirmation process within this accounting period based on actual sales of the goods. If the accounting deadline is missed, the competent tax authority will recover any export tax refunds that have already been processed.

There are three scenarios to consider during accounting:

Scenario 1: The goods have already been sold at the time of accounting.Confirm any discrepancies between the tax refund amount calculated based on actual sales and the advance export tax refund amount. If there are no discrepancies, confirm that ”no adjustment to the declaration is required”; if there are discrepancies, confirm that ”an adjustment to the declaration is required” and submit the adjusted declaration.

Scenario 2: The goods have not yet been sold at the time of accounting.Confirm that ”the declaration needs to be adjusted,” pay back the full amount of the advance export tax refund, and complete the accounting procedures. Once the goods in question are sold, resubmit the declaration to process the export tax refund.

Scenario 3: It is necessary to change the tax refund (or exemption) method or withdraw the export tax refund (or exemption) filing.You should first complete the accounting for the advance export tax refund. Once the accounting procedures are finalized and the advance export tax refund has been settled, proceed in accordance with current regulations.

Adjustments to the specific procedures for reporting and refunding advance export tax rebates: When calculating and reporting export tax rebates for the current period, taxpayers must first use a negative amount to fully offset the reported advance export tax rebate data from the previous period, and then resubmit the report in accordance with current regulations based on the actual sales of the goods.

If the calculation of a taxpayer’s tax refund for the current period results in a negative amount, manufacturing enterprises shall carry it forward to the next period to continue offsetting taxes, while foreign trade enterprises shall pay the additional tax; if the amount is positive, the tax authorities shall process the export tax refund in accordance with current regulations.

Core Points:We recommend setting up a system reminder for April 30 of the following year. Mr. Chen from Dongguan made a mistake right here—he didn’t realize until just before the deadline that his goods weren’t selling well and he needed to pay additional taxes.

05

Three Red Lines: A Guide to Avoiding Pitfalls in the 2026 Audit Upgrade

In 2026, compliance audits for export tax rebates will continue to intensify, with greater emphasis placed on the authenticity of trade and the consistency of data across the entire supply chain. There are three red lines that sellers must never cross—

Red Line 1: Filing a tax refund claim using fraudulent input invoices.During audits, input invoices are cross-checked against customs declarations, purchase documents, and warehouse data; any discrepancies can easily trigger a tax anomaly.

Red Line 2: Deliberately overstating the value of goods to fraudulently claim tax refunds.Once a case is determined to involve tax evasion, taxes will be collected in accordance with the *Tax Collection and Administration Law*, along with late payment penalties and a fine ranging from 0.5 to 5 times the amount of taxes evaded or underpaid. In serious cases, the matter will be referred to judicial authorities.

Red Flag 3: Goods are listed under the 9810 tariff code, but they are not actually shipped to an overseas warehouse for sale.”This is a major problem area identified in the 2026 audit.” While "hanging up the 9810 number to sell tickets" may seem like a quick fix in the short term, it creates significant tax and operational risks in the long run.

Seller Self-Checklist (Eight Things to Do Before Launch):

First, the company has completed the filing for export tax rebates (or exemptions).

Second, has the company completed the customs registration for cross-border e-commerce enterprises? (For 9810 operations, customs has eliminated the requirement for separate special registration of overseas warehouses; electronic information regarding overseas warehouse reservations must be submitted during customs clearance.)

Third, we have already obtained the export goods declaration form with regulatory code 9810.

Fourth, maintain compliant and valid input invoices.

Fifth, keep complete records of all documentation related to booking or leasing overseas warehouses.

Sixth, a complete and traceable sales ledger has been established.

Seventh, the ability to track inventory status by batch.

Eighth, clearly keep in mind the deadline for the advance tax refund accounting period.

This self-inspection checklist isn’t particularly complicated, but the sooner you get it in order, the less hassle you’ll have. If you wait until the tax authorities come to conduct an on-site audit to rush to gather the necessary documents, it’s often too late.

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