Exporting from China: Tax and Customs Routes for Cross-Border Sellers
Updated 2026-08-21
Exporting from China involves two separate decisions that sellers often mix up. First, how customs treats the shipment: general trade (code 0110), retail e-commerce (9610), B2B direct export (9710), or overseas-warehouse export (9810). Second, how VAT is treated at export: claim a refund with supplier VAT invoices, take the invoice-free exemption in a comprehensive pilot zone, or pay no VAT at all for certain goods. The customs code does not decide your refund; your invoices and eligibility do.
Unsure if these rules apply to you?
Two decisions, not one
Sellers often ask "which code should I declare?" as if the code settles everything. It does not. Chinese export compliance splits into a customs layer and a tax layer.
The customs layer is the supervision code on your declaration: 0110 general trade, 9610 e-commerce retail, 9710 cross-border e-commerce B2B direct export, or 9810 overseas-warehouse export. Each code has its own data requirements and clearance channel.
The tax layer is what happens to VAT: a refund tied to supplier VAT invoices, the invoice-free exemption for pilot-zone sellers without purchase documents, or exemption without refund. Which tax treatment you get depends on your invoices, your registration, and the goods, not the four digits on the customs form.
Route 1: General trade with VAT refund
General trade (supervision code 0110) is the traditional route: a company with a customs filing declares goods out, holds VAT invoices from suppliers, and applies to the tax authorities for an export VAT refund.
The refund rate is set per HS code in the official export refund rate library and changes over time, so do not rely on a figure quoted in a forum post. Look up the current rate for your exact HS code in the e-tax bureau or your local tax authority's refund-rate query before pricing.
This route suits sellers whose suppliers issue proper VAT invoices and whose volumes justify the paperwork. If invoices are missing or inconsistent, the refund claim is the first thing to break.
Route 2: Invoice-free exemption in comprehensive pilot zones
If your goods are exported from a comprehensive pilot zone for cross-border e-commerce and you cannot obtain valid purchase documents, the export can qualify for VAT and consumption tax exemption under Caishui [2018] No. 103, in force since 1 October 2018.
Three conditions must all be met: the exporter is registered in the pilot zone and logs the export details on the local online service platform; the goods clear customs at the pilot zone's customs as e-commerce exports; and the goods are not on the list of goods whose export refund or exemption has been withdrawn.
Exemption means you owe no output VAT on the export, but there is no refund of input VAT either. It is the practical route for small sellers buying from markets or factories that do not issue invoices.
Route 3: E-commerce customs codes 9610, 9710, 9810
9610 covers e-commerce retail goods: individuals or e-commerce enterprises transacting through online platforms and clearing parcels under the "list release, summary declaration" model, added by Customs Announcement No. 12 of 2014.
9710 covers cross-border e-commerce B2B direct export: a domestic enterprise completes the transaction with an overseas enterprise through a platform and ships the goods directly to that buyer. 9810 covers overseas-warehouse export: goods ship first to an overseas warehouse, and platform transactions deliver them to buyers from there. Both codes were introduced by Customs Announcement No. 75 of 2020 and rolled out to all customs nationwide by Announcement No. 47 of 2021.
The customs code and the tax route combine freely in principle: a 9810 shipment can still claim a refund if the exporter has invoices and meets refund requirements, or take the pilot-zone exemption if it does not. Decide the code from your logistics model; decide the tax treatment from your invoices.
A simple decision path
Step 1. Identify the buyer and the flow. Consumer parcels shipped straight from China point to 9610. Platform sales to overseas businesses point to 9710. Stock pre-positioned in an overseas warehouse points to 9810. Classic container trade without a platform sits in 0110.
Step 2. Check your invoices. Supplier VAT special invoices in hand: check the current refund rate for your HS code and weigh a refund claim. No invoices and registered in a comprehensive pilot zone: check the exemption conditions above.
Step 3. Sort out registrations before the first shipment: the customs filing for the declaration entity, and for 9810 the overseas-warehouse business model filing at your local customs. Then match your HS codes and declaration elements to the goods.
Registration and filing obligations
Exporters file with customs as declaration entities under the Customs Provisions on Declaration Entity Filing (Customs Order No. 253, in force since 1 January 2022).
Enterprises taking part in cross-border e-commerce B2B export (sellers, platforms, logistics providers) file with the local customs and mark the matching e-commerce enterprise type. Enterprises running the 9810 overseas-warehouse model complete an additional overseas-warehouse business model filing; once filed, the model can be used at customs nationwide.
HS classification is the declarant's responsibility under the Customs Provisions on Commodity Classification (Customs Order No. 252). Wrong classification can cascade into wrong refund rates, wrong declaration elements, and customs queries.
Taxes on the destination side
Chinese export rules are only half the picture. The buyer's country decides import duty and import VAT or GST, and for consumer sales often the marketplace collects it.
For the EU, low-value consignment relief of €150 or less runs through IOSS; see the IOSS registration guide. For the US, check how Section 301 and de minimis rules land on your category before promising a landed price.
Use the tariff and landed-cost tools on this site to sketch the destination-side cost, and treat the result as an estimate, not a bill.
Primary sources
This page is grounded in the primary materials below. Rules change, so open the source and confirm the current version before acting.
- GAC Announcement 2014 No. 12 (adding supervision code 9610)
- GAC Announcement 2020 No. 75 (B2B export pilot, codes 9710/9810)
- GAC Announcement 2021 No. 47 (nationwide rollout of B2B export pilot)
- Caishui [2018] No. 103 (invoice-free exemption in pilot zones)
- Customs Order No. 252 (commodity classification provisions)
- Customs Order No. 253 (declaration entity filing provisions)
- GAC supervision code table (0110 general trade)
FAQ
Does using 9610, 9710 or 9810 automatically give me a VAT refund?+
No. The customs code decides the clearance channel, not the tax treatment. A refund still requires supplier VAT invoices and meeting export refund conditions; without invoices, the comprehensive pilot zone exemption may be the available path.
What is the difference between 9710 and 9810?+
9710 is B2B direct export: goods ship straight to the overseas buyer after a platform transaction. 9810 is overseas-warehouse export: goods ship to the warehouse first and are delivered to buyers from there. 9810 additionally requires an overseas-warehouse business model filing at your local customs.
Can I get a refund on 9810 overseas-warehouse exports?+
In principle yes, if the exporter holds valid VAT invoices and meets the export refund requirements; otherwise the pilot-zone invoice-free exemption may apply. Confirm the treatment for your setup with the local tax authority, because overseas-warehouse sales realization timing affects refund paperwork.
Do I need to register with customs before exporting?+
Yes. Declaration entities file with customs under Customs Order No. 253 (in force since 1 January 2022). Cross-border e-commerce B2B participants also mark their e-commerce enterprise type, and 9810 users complete the overseas-warehouse model filing.
Where do I check the export refund rate for my product?+
Refund rates are set per HS code in the official export refund rate library and change over time. Check the current rate in the e-tax bureau's export refund rate query or your local tax authority's website rather than relying on quoted figures.
Where can I read the detailed pages for each topic?+
Code selection: /q/export-code-9610-9710-9810. Exemption vs refund: /q/invoice-free-exemption-vs-refund. HS codes with customs declarations: /q/customs-hs-code-matching. Refund procedure: /q/export-refund-how-to. Declaration basics: /q/customs-declaration-how-to.
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