11号公告落地免税节奏被前置!附上2026六大报关模式深度解读!
发布时间:2026-03-09

Enterprise Caiying Group provides the U.S. company / Singapore company / Japan company / Thailand company / Malaysia company / Canada company / Mexico company / Brazil company / UK company / France company / New Zealand company / Vietnam company / Indonesia company / Dubai company and other foreign companies registered in the relevant business and taxation services, but also to provide Hong Kong company / Shenzhen company / Guangzhou company / Shanghai company / Hangzhou company / Beijing company / Hainan company and other domestic companies registered corporate services, company annual audit / bookkeeping tax / payment of MPF / change of information / bank account / ODI filing / BVI registration / tax compliance / cross-border e-commerce accompanied running Beijing company / Hainan company and other domestic companies registered corporate services, company annual audit audit / bookkeeping and tax returns / payment of MPF / change of information / bank account opening / ODI filing / BVI registration / tax compliance / cross-border e-commerce accompanied by running on behalf of the operation of the enterprise one-stop service, you have the need or interested in any time to drop me (phone and WeChat consulting: 13045886252).

According to the Announcement of the Customs Tariff Commission of the State Council on the Tariff Adjustment Program for 2026, the import tariff rates and tariff lines of certain commodities will be adjusted from January 1, 2026 onwards.

The General Administration of Customs has split the 10-digit customs commodity numbers for the commodities with relevant import and export tax policies for the non-full tax items and compiled the corresponding numbering table, and the enterprises importing and exporting the relevant commodities should declare the numbering in accordance with the annexes; and the commodity numbering of the non-full tax items with the application of the most-favored-nation tariff rate for the information technology products will be executed in accordance with the annexes to the Announcement 207 of the General Administration of Customs in 2024. (If you need the commodity number table, please write to 13045886252 to get it.)


01 Original announcement::

海关总署公告2025年第260号(关于执行2026年关税调整方案及有关事宜的公告)根据《国务院关税税则委员会关于2026年关税调整方案的公告》(税委会公告2025年第11号)公布的《2026年关税调整方案》,自2026年1月1日起,对部分商品的进口关税税率和税目进行调整,现就执行相关关税政策事宜公告如下:

I. Customs Commodity Number Declaration Requirements Involving Relevant Import and Export Tax Policy Measures

In order to implement the 2026 temporary duty rate for import and export commodities and the import link VAT and consumption tax policy for some commodities, the General Administration of Customs has split the 10-digit customs commodity numbers for the commodities of the non-full tax items that are subject to the above import and export tax policy, and compiled the "Table of Customs Commodity Numbers Corresponding to the Commodities Subject to the Temporary Rate of Import and Export Non-full Tax Headings in 2026", "Table of Customs Commodity Numbers Corresponding to the Partial Commodities Subject to the VAT and Consumption Tax Policy on Import and Export in 2026" (Annexes 1 and 2). Table of Customs Commodity Numbers Corresponding to Some Commodities under Import and Export Non-full Tax Heads Applying Import Link VAT and Consumption Tax Policies in 2026 (see Annexes 1 and 2)

Enterprises importing and exporting the relevant commodities under the above import and export tax policies should declare the commodity numbers listed in the corresponding annexes of this announcement, and the scope of application of the policies shall be subject to the provisions of the Tariff Adjustment Program 2026 and the relevant import VAT and consumption tax policies.

For commodities with MFN duty rates for information technology products under non-full tariff lines, their 10-digit customs commodity numbers continue to be implemented in accordance with Annex 1 of General Administration of Customs Announcement No. 207 of 2024, "Table of Corresponding Customs Commodity Numbers of Information Technology Products under Non-full Tariff Lines of Import and Export for the Year of 2025".

II. Other related matters

Adjustments to import tariff rates and tariff lines for certain commodities in the Tariff Adjustment Program for 2026, as well as the Customs Import and Export Commodity Tax-Related Standardized Declaration Catalogue (2026 Edition) are available through the General Administration of Customs portal for reference in customs clearance declarations.

Notice is hereby given.

Annex: 1.2026 Table of Customs Commodity Numbers Corresponding to Commodities with Provisional Duty Rates for Import and Export Non-full Duty Headings.xlsx

2.2026 Table of Customs Commodity Numbers Corresponding to Partial Commodities of Import and Export Non-full VAT and Consumption Tax Policies.xlsx

General Administration of Customs (GAC)

December 31, 2025

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02  免税节奏被前置

风向先到,规则随后。

此前国家税务总局在《中华人民共和国增值税法实施条例(征求意见稿)》中提到,免税申报以36个月为限,逾期视同内销补税;委托出口手续不完备的,责任主体亦可能被直接认定。

而如今,随着财政部、国家税务总局发布的公告2026年第11号(下文简称“11号”公告)落地,上述导向也开始真正的“落地成章”。

据了解到,9810海外仓模式的特点在于链路更长、结算更慢、业务要素更分散。也因此,过去不少卖家将免税申报与资料归集放在相对靠后的位置——“先把货送出去,税务再慢慢处理”。

但11号公告落地后,免税这件事很难再继续“后补”。

具体而言:

其一,免税申报期限首次明确,36个月成为“硬节点”

新规明确:免税申报需在货物报关出口之日起36个月内完成(以海关出口报关单注明的出口日期为准),逾期未申报视同内销征税。

同时,新规也划出分界:2025.12.31前的出口业务不适用该36个月规则,仍按原政策执行。

对卖家而言,关键不在“多了一个期限”,而在于9810免税自此有了明确的时间节点。过去还能“拖一拖”的票据与申报节奏,后续需要提前纳入经营节奏。

其二, 备案不再“单独一环”,材料反而更关键

新规取消了“单独办理免税备案”的动作,但要求企业先完成出口退(免)税基础备案,并按规定留存9810出口全套单证。

值得注意的是,这一点容易被误读为“流程简化”。但业内人士认为,更准确地理解是“前端少一步、后端更看材料”:不再强调多跑一次备案流程,但对链路材料的完整性与可核查性提出了更高要求。

换句话说,免税能否站得住,越来越取决于卖家能否把“订单—物流—报关—仓配—销售(如适用)”这些关键环节对得上、串得起来,而不是材料单点“看起来齐全”。

其三,收汇要求放宽,但把“事后追责”写得更明确

此外选择免税无需按退税要求完成收汇/视同收汇。对海外仓这类回款周期不规则、结算方式多样的业务而言,这在一定程度上降低了前端操作摩擦。

但同时,新规也明确了后手:若后续该笔业务被查实属于征税情形(如虚假业务、伪造单证等),则需改按征税政策补税。

这意味着,收汇不再作为统一门槛,但真实性审查与追责路径更清晰。

因而总体来看,11号公告并未改变“出口业务可享受免税”的政策框架,但对9810海外仓卖家把两件事说得更清楚:时间要卡住,证据要闭环——按期申报、链路可证、责任可界定。

免税不再适合后置处理,而需要提前安排到流程中。如果你的企业需要税务规划或者税务合规优化方案,可以随时咨询(微信同号:13045886252)▼▼▼

03 六大报关模式

Speaking of the new customs policy, it is inevitable that people think of cross-border export customs clearance, and today we share 6 major customs clearance modes to see which one is suitable for you?

跨境出口报关模式的选择确实是个技术活,因为报关的方式有很多,外贸人几乎都踩过 “报关模式选错” 的坑:

有人用 9610 报大额 B2B 订单,导致无法享受出口退税;有人明明符合 1210 保税备货条件,却用 1039 市场采购,白白多缴了增值税。

In fact, there are 6 major customs clearance models(0110, 1210, 9610, 1039, 9710, 9810)It not only determines the logistics process, but also directly affects the tax cost -- choosing the right model can save 50% tax burden, while choosing the wrong one may trigger the audit to make up the tax.

Today we will talk in detail about the 6 major modes of customs clearance for cross-border e-commerce exports.

1) Mode 0110 (general trade)

0110 is the most traditional and widespread form of "general trade" export, which is the cornerstone of international trade.

Features:This is the most traditional B2B export mode, you need to provide a full set of documents such as contracts, invoices, packing lists, etc., the tax rebate process is mature and stable. It is the traditional mainstream way of foreign trade , cross-border e-commerce can also be done through the Hong Kong company structure, go 0110 mode.

Applicable Scenarios:All domestic manufacturing enterprises or trading companies with import and export rights to trade in bulk, high value, non-platformized traditional goods, such as machinery and furniture.

2) 9610 model (cross-border e-commerce retail direct mail)

9610 is the "standard mode" of cross-border e-commerce B2C, and the process is "sell the goods first and then collect the goods for customs clearance": after the overseas consumer places an order and pays for it, the enterprise will unify the multiple small package orders and pack them, and send them to the buyer through express / postal service after customs clearance in bonded area, and then regularly Aggregation and declaration of tax refund.

Features:Greatly enhance the customs clearance efficiency of small parcels, the use of "single checking and release, summary declaration" mode of customs clearance, the need to push the order, payment, logistics, three single information to the customs system.

Applicable Scenarios:Do cross-border B2C retail sellers (such as Amazon individual sellers, independent station C sellers), small and micro-enterprises, the order amount is small, high frequency, light and small pieces of direct mail, but the lack of input ticket is more difficult to refund the tax.

3) 9710 model (cross-border e-commerce B2B direct export)

9710 is a separate regulation for B2B transactions concluded through cross-border e-commerce platforms in traditional general trade (0110).

Features:Domestic enterprises through the cross-border e-commerce platform and foreign enterprises to reach a deal directly after the export of goods, the declaration of the platform orders can be used to replace the paper contract, simplify the process, no single-ticket amount limit. 2025 has been abolished from the mandatory requirements for the receipt of information, to help the digital transformation of traditional foreign trade .

Applicable Scenarios:Online platform B2B trading for companies doing cross-border B2B trade (e.g. supplying overseas distributors, superstores).

4) 9810 model (cross-border e-commerce export overseas warehouse)

9810 is the regulatory code for the mode of "exporting cross-border e-commerce goods to overseas warehouses before selling them". Enterprises first send goods in bulk to overseas warehouses, and then ship them to buyers from overseas warehouses after the transaction. The key to taxation is that "goods leaving the country are regarded as exported, and can apply for tax refund", and there is no need to declare customs again for subsequent shipments from overseas warehouses.

Features:The process is simplified, leaving the country means exporting, entering the warehouse means tax refund. As long as the goods enter the overseas warehouse recognized by the Customs, the enterprise can apply for tax rebate with the customs declaration, without waiting for the actual sales, which greatly alleviates the financial pressure on the enterprise. However, it is necessary to complete the filing of the overseas warehouse and retain the sales vouchers, otherwise there is a tax risk, and this model is currently being tried by many sellers.

Applicable Scenarios:Sellers operating overseas warehouses, such as Amazon FBA, independent station overseas warehouse delivery, have long-term stocking needs.

5) Model 1039 (Market Purchase Trade)

1039 The full name is "Market Purchase Trade Modes", initially piloted from Yiwu, Zhejiang Province, and now extended to more than 30 pilot regions such as Guangzhou and Jiangsu Province.

Features:You can export compliantly without input invoices and pay VAT at the approved rate (usually approved rate 0.8%-1.2%). Only for use by registered operators in the pilot area , it is getting harder and harder to register as a self-employed person now.

Applicable Scenarios:It applies to small commodity exports of individual households/non-ticketed goods purchased in state-recognized market clusters (e.g., Yiwu) with a single-ticket value of not more than US$150,000, and is required to be registered as an operator in the pilot region.

6) 1210 model (bonded cross-border trade e-commerce)

1210 is also known as "bonded stock preparation for export", which simply means "stock up the goods in the bonded area first, and then clear the customs and ship the goods when there is an order".

Features:The biggest advantage is "advance tax refund", to realize "sell one, out of the warehouse one". It can also be used for export front stocking, and the new policy in 2025 requires that tax rebates need to provide full logistics vouchers. Must be stationed in the special customs supervision area, non-special area can not enjoy the "tax rebate in the area"; in addition, when the goods are issued from the bonded area, to ensure that the "order, waybill, payment list" three single consistent, data inconsistency will affect the tax rebate.

Applicable Scenarios:Enterprises with stable inventory turnover, importing e-commerce or exporting front warehouses, and utilizing bonded policies to achieve flexible stocking.

If you need to register Shenzhen company / Guangzhou company / Shanghai company / Hangzhou company / Beijing company / Hong Kong company / Hainan company and other domestic company registration of related business services, but also to provide U.S. companies / Canadian companies / Mexican companies / Brazilian companies / U.K. companies / French companies / New Zealand companies / Japanese companies / / Singapore companies / Thailand companies / Vietnam companies / Malaysia companies and other foreign companies Registered related business tax services, company annual review / bookkeeping tax / payment of MPF / change information / bank account / ODI filing / cross-border e-commerce accompanied by running on behalf of the operation of the enterprise one-stop service, you can add my WeChat (phone with V: 13045886252) at any time to consult the ↓ ↓↓↓ 

04 匹配适合自己的报关模式

Provide a selection logic reference.

1) Match the core model to the business scenario

Bulk B2B trade: preferred 0110 (general trade) with standardized process and stable tax refund.

Small Packet Direct Mail (B2C): Choose 9610, a customized clearance solution for cross-border retail.

Online B2B transactions: Adopt 9710 and enjoy the convenience of digitalized customs clearance.

Operate overseas warehouse: match 9810, realize "export tax refund", optimize capital flow.

Individuals/uninvoiced small goods: try 1039 (subject to pilot areas) to solve the "uninvoiced tax exemption" problem.

Import e-commerce or export front warehouse: layout 1210, the use of bonded policy to achieve flexible stocking.

(2) Consideration in the context of different stages of development of enterprises

Start-ups/Micro and Small Enterprises (MSEs): Priority can be given to 9610 (Direct Mail) or 1039 (Market Purchase, if eligible), which are relatively flexible in operation and have lower thresholds, for a quick start-up of business.

Growing/scaling enterprises: With the increase in cargo volume and the need for standardization, they should turn to 0110 (general trade), 9710 (B2B) or 9810 (overseas warehouse) to obtain better tax rebate policies and achieve compliance and sustainable development.

3) Core points for weighing compliance and convenience

(1) Incoming invoices:是否能取得合规的进项发票以完成退税有票、求退税:优先选 0110/9710/9810/9610(根据交易和物流模式选择)无票、求便利: 符合条件可走 1039

(2) Overseas warehouse costs:是否需要及能否承担海外仓的备案与管理成本直发小包选 9610海外仓备货选 9810

(3) Value of goods and logistics:Small value, high frequency selection 9610 large value, need to hoard selection 1210, 9810 professional market procurement selection 1039

Final Summary:In the future, data collision will become the norm, and compliance means competitiveness. Foreign trade enterprises need to combine their own situation and stage of development, choose the most suitable customs clearance channel, enjoy the policy dividend at the same time, to ensure that the business long-term compliance and sound development.

If you need to register Shenzhen company / Guangzhou company / Shanghai company / Hangzhou company / Beijing company / Hong Kong company / Hainan company and other domestic company registration of related business services, but also to provide U.S. companies / Canadian companies / Mexican companies / Brazilian companies / U.K. companies / French companies / New Zealand companies / Japanese companies / / Singapore companies / Thailand companies / Vietnam companies / Malaysia companies and other foreign companies Registered related business tax services, company annual review / bookkeeping tax / payment of MPF / change information / bank account / ODI filing / cross-border e-commerce accompanied by running on behalf of the operation of the enterprise one-stop service, you can add my WeChat (phone with V: 13045886252) at any time to consult the ↓ ↓↓↓ 

05  Choose Enterprise Caiying Group as a long-term partner

🏆 Why choose Enterprise Finance? --Professional strength, global trust

Enterprise Caiying Group, since its establishment in 2015, has always been adhering to the mission of "empowering every entrepreneurial dream", focusing on providing one-stop globalized industry, commerce, finance and tax and business services for enterprises.

Our bottom line, from the deep precipitation and authoritative certification:

✅ Service Scale Witnesses Reputation: Accumulated services for more than 300,000+ enterprises, long-term cooperation with more than 50,000+ customers.

✅ Global Network Local Support: Branches are set up in Beijing, Guangzhou, Shenzhen, Hong Kong, Southeast Asia, and the United States, with services covering Asia, Europe, and the Americas.

✅ Official certification qualification escort: with 3 Hong Kong government certified licensed secretarial firms, a U.S. branch and a self-employed Hong Kong accounting firm, and at the same time is the vice president of the Shenzhen Agency Bookkeeping Association, etc., to ensure that the service is fully compliant and reliable.

The four core advantages of Enterprise Caiying's overseas company registration service:

🔹 1. A team of experts to guide you throughout the process

Our team of nearly 400 professionals consists of senior lawyers, accountants, tax accountants and cross-border business consultants. They are well versed in international regulations, handle thousands of high-end cases annually, and can provide optimal customized solutions from structural design to on-the-ground implementation.

🔹 2. digitally empowered, smart and efficient

We have spent 20 million RMB to research and develop our own digital system "Echobo", which realizes process standardization and progress visualization. The integration of AI intelligent analysis can provide quick insight into demand and assist in generating solutions, making complex affairs clear, transparent and efficient.

🔹 3. Eco-links, extra value

We connect over 500,000+ entrepreneurs with domestic and international associations. By regularly organizing cross-border salons, tax law seminars and other activities, we not only solve registration problems, but are also committed to linking resources and creating business opportunities for you.

🔹 4. Full-cycle accompaniment for worry-free sailing

Our services go beyond "successful registration". We provide a full life cycle of services from early consultation, mid-term implementation, to late financial and tax declaration, annual audit and maintenance, and compliance consulting, to become your long-term and stable partner for overseas expansion.

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Information reference: The content of this article is synthesized from the internal materials of Enterprise Caiying and relevant public network information.

Content Editor: This article was edited and designed by the Operations Department of the Enterprise Caiying Group.

Warm reminder: The relevant policies, conditions, time limits, fees and other information described in this article may be subject to dynamic adjustments, please refer to the latest official announcements or the actual application of the specific circumstances prevail.

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  • Corporate Tax Compliance
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  • Customs clearance mode