New regulations on export tax rebates will take effect in 2026, and the 10 major changes will directly impact the bottom line of every foreign trade company. For companies operating in compliance with regulations, the new rules are a boon; for those with lax management, however, they represent red lines at every turn.

This is not an exaggeration. In 2026, export tax rebate policies will undergo a round of systemic adjustments: on the one hand, the ”9810 overseas warehouse” will feature ”tax rebates upon departure,” tax exemptions for returned goods, an increased declaration limit for “9610” shipments, and a paperless filing process—making tax rebates faster and simpler; on the other hand, there will be a standardization of foreign exchange receipt deadlines, the integration of tax and foreign exchange data, and a comprehensive tightening of requirements for tracing violations and retaining documentation. To summarize using official terminology, it can be encapsulated in eight characters: “Combining liberalization with regulation, driven by digital intelligence.”

Simply put, the new regulations provide greater ”freedom” while also ensuring more precise ”regulation.” These two aspects are not contradictory: benefits are granted to those who comply, while red lines are drawn to curb speculators. Which side you fall on depends on whether your accounting records and documentation can withstand scrutiny under the new regulations. Below, we break down the 10 major changes one by one.

The reporting criteria, foreign exchange receipt timelines, and documentation requirements covered by the new regulations are all closely intertwined; trying to figure them out on your own can easily lead to oversights. Qicaiying’s e-commerce compliance accounting service can help you sort out the accounting records and tax refund documents for multiple platforms and stores all at once. Qicaiying Group specializes in providing company registration services for domestic and international locations, including Shenzhen, Guangzhou, Shanghai, Beijing, Hangzhou, Hong Kong, the United States, Japan, South Korea, Southeast Asia, Singapore, the British Virgin Islands (BVI), and the Cayman Islands. We also offer annual company reviews and audits, bookkeeping and tax filing, tax compliance, information updates, bank account openings, ODI and FDI filings, and other corporate services; Hong Kong residency applications, renewals, and permanent residency services; Singapore EP application services; and cross-border e-commerce mentoring and managed operations—all as part of our one-stop service. If you have any needs or are interested, please feel free to contact me at any time (Consultation Hotline: 18676749275, add WeChat: Qicaiyingjituan).

I. Accelerated Tax Refunds: ”9810” Tax Refund Upon Departure, Tax-Free Returns, and Increased 9610 Quotas

Change 1: The ”9810 Overseas Warehouse Model” now allows for “tax refunds upon departure.” Under the previous overseas warehouse model, sellers had to wait for confirmation of actual overseas sales before applying for a tax refund after goods had left the country, resulting in a lengthy period of capital tie-up. The new regulations specify that for goods under the 9810 program, a preliminary tax refund declaration may be filed immediately after customs clearance upon departure, with final settlement to be processed later based on actual sales data. For sellers stocking goods in overseas warehouses, the cycle for recovering tax refund funds has been significantly shortened, providing tangible relief from the financial pressure of stocking large quantities of inventory during peak seasons.

Change 2: Tax Exemption for Returned Cross-Border E-Commerce Goods. Goods exported under the 1210, 9610, 9710, and 9810 modes that are re-imported in their original condition within the specified time limit (6 months) are exempt from import duties, import-stage value-added tax, and consumption tax. This policy will remain in effect until 2027. In the past, returning goods required the payment of back taxes, leading many sellers to opt for abandoning the goods instead; now that compliant returns no longer incur tax burdens, the profit structure for product categories with high return rates has significantly improved.

Change 3: The declaration limit for the 9610 category has been raised. The declared value limit per package under the 9610 category has been increased from 5,000 yuan to 10,000 yuan. Don’t underestimate this figure—in the past, a large number of high-unit-price 3C digital products, small appliances, and light-luxury home goods were forced to be split into separate shipments due to exceeding the per-item limit, causing logistics costs to skyrocket. With the limit now doubled, it’s possible to declare the entire order as a single shipment, thereby reducing both operational costs and customs clearance risks.

It is important to note that these three ”accelerated procedures” are all contingent upon the accuracy of the data. For ”Tax Refund upon Departure,” the pre-declaration must be cleared within the specified time limit; for duty-free goods returned to the supplier, the goods must be returned in their original condition with all required documentation; and declarations within the 9610 quota must correspond one-to-one with platform orders and logistics tracking records. The broader the channels provided by the policy, the more frequently data will be subject to spot checks and comparisons—speed is for those who comply, not for those who operate haphazardly.

Taken together, these three changes send a clear signal: Regulators are encouraging companies to ”go global, sell more, and bring profits back,” prioritizing tax refund efficiency for cross-border businesses that are genuinely conducting business.

II. Tightening of Foreign Exchange Receipts: Standardized Time Frames, Networked Data, and Automatic Alerts for Anomalies

Change 4: A nationwide uniform deadline for foreign exchange collection. The deadline for collecting foreign exchange from exports has been uniformly adjusted to April 30 of the year following the customs clearance of the exported goods. Previously, local authorities applied inconsistent standards regarding the deadline for foreign exchange collection, making it easy for companies to inadvertently violate regulations in ”gray areas”; now that a single nationwide standard is in place, all export companies must incorporate foreign exchange collection into their strict management practices.

Change 5: Integration of tax and foreign exchange data. The tax and foreign exchange systems have achieved data interoperability, enabling automatic cross-checking of tax return data, customs declaration data, and foreign exchange receipt data. The system automatically triggers an alert whenever discrepancies arise between tax returns and foreign exchange receipts, foreign exchange receipts are overdue, or the source of foreign exchange receipts is abnormal. This means that the previous loophole—where ”one set of figures was reported while another set was used for actual receipts”—has been completely eliminated. Whether tax refunds are ultimately received depends on whether the foreign exchange receipt data is in good standing.

Change 6: Simplifying Filing and Implementing Paperless Reporting. Procedures are being streamlined simultaneously: electronic filing for export tax refunds (or exemptions) has been fully implemented, and overseas warehouse registration is now handled paperlessly, eliminating the need for enterprises to repeatedly submit paper documents. The goal of this institutional design is to ”let data do the running so enterprises don’t have to”—but the prerequisite remains that every piece of your data must withstand verification.

Once automatic cross-checking of foreign exchange receipts and tax filing data begins, companies with discrepancies between their books and actual transactions will have virtually no grace period. If you’re unsure whether your payment transaction records and tax filing data will match, we recommend conducting a specialized audit before the filing season begins. Qicaiying’s bookkeeping, tax filing, and e-commerce compliance services can help you reconcile platform transaction records, payment records, and tax filing data on a transaction-by-transaction basis, eliminating potential red flags in advance. 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 company audits, bookkeeping and tax filing, tax compliance, information changes, bank account openings, ODI and FDI filings, and other corporate services; Hong Kong residency applications, renewals, and permanent residency services; Singapore EP application services; and cross-border e-commerce coaching 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).

III. Tighter Regulations: 36-Month Retroactive Review, 10-Year Retention, and Four Categories of High-Risk Cases

Change 7: 36-Month Retroactive Enforcement Period for Violations. The retroactive enforcement and penalty period for tax-related violations by export companies has been explicitly set at 36 months. What does 36 months mean? A batch of documents from three years ago could still be dug up today to hold the company accountable. This is a wake-up call for companies with a ”reactive” management style—compliance must be an everyday practice, not a last-minute response when an audit is underway.

Change 8: Documents must be retained for 10 years. The retention period for documents, ledgers, and materials related to export tax rebates has been extended to 10 years. For many small and medium-sized enterprises, this is virtually equivalent to ”permanent retention.” Original supporting documents across the five key processes—orders, logistics, customs clearance, foreign exchange receipt, and invoicing—are all critical; a missing link in any one of these could affect the outcome of subsequent audits. Companies with paper documents scattered across various locations must establish an electronic archiving system as soon as possible.

Change 9: Four types of high-risk scenarios are subject to enhanced oversight: First, confusion regarding policy types, where goods not eligible for a particular tax refund policy are incorrectly declared under that policy; second, fraudulent overseas consumption, where export transactions or overseas sales are fabricated to fraudulently obtain tax refunds; third, unclear accounting for processing trade, where disorganized records for import-processing and in-bond processing lead to inaccurate calculation of tax refund amounts; fourth, operational errors during the transition period, involving the incorrect application of policies during the transition from old to new regulations. These four scenarios are precisely the primary focus of tax audits.

Change No. 10, which is also the core logic underpinning all the changes, is ”combining deregulation with effective oversight, driven by data and intelligence.” Where deregulation is warranted, it should be implemented with full force; where oversight is needed, it should be enforced thoroughly using data. In the future, success in export tax rebates will not depend on the ability to exploit policy loopholes, but rather on management capabilities that ensure data consistency, complete documentation, and standardized processes.

IV. How Should Foreign Trade Companies Adapt to the New Regulations?

In response to these 10 major changes, companies can take a ”three-step approach.”

Step 1: Get your accounting records in order. Consolidate the financial records across multiple platforms, stores, and entities, ensuring that each order, shipping detail, and payment is matched on a transaction-by-transaction basis so that every declaration is fully documented. This step is a prerequisite for the next two steps. Step 2: Put foreign exchange receipt management on the agenda. Incorporate payment deadlines, sources of receipts, and bank statements into your daily management routine. Set up alerts for upcoming deadlines to ensure ”overdue foreign exchange receipts” never appear in your records. Step 3: Digitize your document archives. In accordance with the 10-year retention requirement, centrally archive customs declarations, bills of lading, invoices, platform orders, and foreign exchange receipts to ensure they are readily accessible and available for filing at any time.

In addition, there are three issues you should check immediately: Does your declaration code (9610/9710/9810/1210) match your business operations? Do your returned goods meet the conditions for tax exemption, and are all required documents complete? Has the registration for your overseas warehouse been completed through the paperless process? If you cannot answer any of these questions, it indicates a potential risk.

Whether the new regulations are a boon or a red line depends on which side you’re on. If your accounting is in disarray, your supporting documents are missing, and your foreign exchange management is lacking, you won’t be able to capitalize on even the best policy benefits. Qicaiying offers one-stop services for e-commerce compliance accounting, VAT filing, and product compliance, helping export companies keep a tight grip on their finances, eliminate risks, and maximize benefits under the 2026 regulations. 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 more, as well as annual company audits, bookkeeping and tax filing, tax compliance, information updates, bank account openings, ODI filings, FDI filings, and other corporate services; Hong Kong residency applications, renewals, and permanent residency services; Singapore EP application services; and cross-border e-commerce mentoring and managed operations. If you have any needs or are interested, please feel free to contact me at any time (Consultation Hotline: 18676749275, add me on WeChat: Qicaiyingjituan).

“The eight words—”combining deregulation with oversight, driven by digital and intelligent technologies”—capture the essence of the new 2026 export tax rebate regulations. Compliance is your most valuable asset under these new regulations.