A-Jie, who runs an overseas warehouse, shipped his goods to a U.S. warehouse and sold them for a quarter. His finance team told him, ’We can’t process the tax refund until everything is sold,’ so his funds are tied up in the overseas warehouse and can’t be recycled. He heard that starting in 2026, the 9810 procedure will allow for “tax refunds upon departure,” but he’s not sure if his business qualifies.

Meanwhile, sellers offering direct-to-consumer small packages are facing double pressure from EU tariffs and the fourth phase of the “Golden Tax” initiative, with their export tax refund claims frequently being blocked by the system. The 2026 export tax refund rules have undergone several changes; this article provides a comprehensive explanation of the 9810 procedure and various regulatory models.

With the implementation of the Value-Added Tax Law in 2026 and the integration of the ’Golden Tax Phase IV” system with the “Five Networks,” cross-border e-commerce tax refunds have shifted from “manual review” to “automated system verification”; if the data does not match, the refund is automatically blocked, leaving no room for human intervention.

01

What is 9810, and what are its advantages?

9810 is the customs supervision method code for ’cross-border e-commerce exports to overseas warehouses.’ Unlike traditional general trade, it is specifically designed for sellers who “first stock goods in overseas warehouses for subsequent local sales.” Starting in 2025, the “tax refund upon departure, tax recalculation upon sale” policy will be implemented nationwide (Announcement No. 3 of 2025 by the State Taxation Administration), and by 2026, it had become the mainstream compliance pathway.

Key Benefit: Sellers can apply for a preliminary tax refund immediately after goods clear customs for export, without having to wait for the actual sale; the tax amount will then be recalculated based on actual sales. For overseas warehouse sellers with high inventory levels, this significantly reduces cash flow pressure.

Convenient Support: Through joint training sessions organized by the tax authorities, customs, foreign exchange authorities, and commerce departments, enterprises can file for 9810 export tax refunds (or exemptions) via the Electronic Tax Bureau and the “Single Window” for international trade; for Category I and II export enterprises with high credit ratings, the tax refund processing time has been reduced to 3 business days.

02

How to Choose Among Six Regulatory Models

9610 (Direct Mail Small Packages B2C): Direct shipping from AliExpress, TikTok, and independent websites. You must first complete cross-border e-commerce business registration, submit a declaration list after the ’three-invoice verification,” and ensure each shipment does not exceed 5,000 RMB. Without an input special invoice, you are only eligible for “tax exemption without an invoice” and cannot claim a tax refund. Suitable for small and medium-sized sellers testing product viability.

9710 (B2B Direct Export): For factory-based, bulk B2B sellers; the process is the same as general trade. This is best suited for tax refunds but does not offer exclusive tax incentives. 1210 (Bonded Stockpiling): A bonded model for imports, primarily used for cross-border imports.

9810 (Overseas Warehouse): This is the ’mainstream” channel mentioned earlier, suitable for sellers focusing on premium products, brand-building, and maintaining stable inventory levels. Choosing the wrong model can result in “unable to claim tax refunds, unable to settle foreign exchange, and unable to avoid audits”; it is essential to select the channel that aligns with the substance of your business.

If you’re facing a similar situation—operating an overseas warehouse and wanting to use the 9810 pre-tax refund process, but aren’t sure how to handle entity qualifications and customs declaration markings—feel free to scan the QR code to add Qicaiying’s online customer service (WeChat/Phone: 18620388671). We’ll help you design a tax refund compliance plan. Feel free to scan the QR code to contact Qicaiying’s online customer service (WeChat/Phone: 18620388671), and we’ll help you sort out this entire process from start to finish.

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03

The fourth singles match is the lifeline.

To claim a tax refund in 2026, the following conditions must all be met: the goods must be sold to an overseas entity or individual; customs clearance must be completed and the goods must have actually left the country; a special customs declaration form for export tax refunds must be obtained, and its information must match the customs electronic records; and the foreign trade enterprise must have a corresponding special VAT invoice that matches the customs declaration form.

The filing deadline has also been tightened: Starting in 2026, export goods must have their tax refund or tax exemption claims filed between the month following customs clearance and April 30 of the following year, and tax refund claims must be filed within a maximum of 36 months; failure to meet these deadlines will result in the goods being treated as domestic sales, requiring the payment of 13% value-added tax. Under the 9810 model, supporting documentation for sales must also be submitted within 15 days of the sale.

Under the "Golden Tax Phase IV" initiative, customs declaration information is directly transmitted to the tax authorities, which can also request data from logistics companies, freight forwarders, banks, and payment platforms—customs declarations, logistics documents, bank statements, and platform orders are all fully integrated and cross-checked, with an alert triggered if any item is missing.

04

Six Common Pitfalls in Tax Refunds

Pitfall 1: Qualification Error: If you are not a general VAT taxpayer and have not filed for export tax refund (exemption), small-scale taxpayers are only eligible for tax exemption and cannot claim tax refunds; using the 122030 market procurement channel results in tax exemption but no refund.

Pitfall 2: Invoice Errors: Only general invoices are available, not special invoices; even a single character discrepancy between the invoice description, specifications, or quantity and the customs declaration form is unacceptable; if a supplier goes missing or becomes uncontactable, the invoice is classified as an ’abnormal document”; if the invoice date is more than 30 days after the export date, it triggers a written inquiry.

Pitfall 3: Customs Declaration Errors: Intentionally misclassifying HS codes to increase the tax refund rate; vague information in consolidated customs declarations by freight forwarders; discrepancies between the operating entity and the entity receiving foreign exchange or claiming tax refunds; 9810 entries fail to include the “overseas warehouse” designation or lack the overseas warehouse code. Pitfall 4: Foreign Exchange Receipt Errors: Receiving overseas payments via personal accounts, WeChat, or Alipay; discrepancies between the entity receiving foreign exchange and the entity filing the customs declaration (e.g., using a Hong Kong company to receive payments); unexplained discrepancies in amounts exceeding 101 TP3T. Pitfall 5: Documentation errors: Documents exceeding the 36-month retention period, failure to file records, or retention period shorter than 10 years. Pitfall 6: Triggering big data alerts.

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05

How to Ensure a Stable Tax Refund in 2026

First, make sure you’ve correctly identified the entity and selected the appropriate code: Register as a general taxpayer and complete the tax refund filing. Select 9810 or 9710 based on the substance of the transaction—don’t use the wrong code just for the sake of convenience. Sellers using overseas warehouses should prioritize the 9810 pre-refund process, as it offers the highest cash flow efficiency.

Second, ensure consistency across the four flows: Contracts, invoices, customs declarations, and foreign exchange receipts must correspond one-to-one, and the ironclad rule is that the exporter must be the same entity that receives the foreign exchange; when using a Hong Kong company to receive payments, conduct thorough due diligence to avoid triggering alerts due to inconsistencies in the entity.

Third, leverage policy benefits: The ’9810’ “Tax Refund Upon Departure,” tax-free purchases without receipts (in comprehensive pilot zones), and the 4% corporate income tax assessment (for eligible companies) all offer legitimate opportunities—provided the underlying business transactions are genuine and all supporting documentation is complete. Treat tax refunds as a compliance initiative, not as a remedy applied after the fact.

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