New forms of foreign trade customs related hot topics Q&A

In recent years, new forms of foreign trade have accelerated innovative development, injecting strong momentum into high-quality development. This issue of 'Reader's Questions' focuses on new forms of foreign trade, answering hot questions for import and export enterprises in the form of Q&A, and helping enterprises operate in compliance.

1、 Regarding cross-border e-commerce export overseas warehouses

（1） What is a cross-border e-commerce export overseas warehouse?
Answer: Cross border e-commerce B2B export, also known as "cross-border e-commerce enterprise to enterprise export", refers to the trade form in which domestic enterprises transport goods to overseas enterprises or warehouses through cross-border logistics and complete transactions through cross-border e-commerce platforms. At present, there are two main business models included in cross-border e-commerce B2B export supervision: cross-border e-commerce B2B direct export (applicable supervision code "9710") and cross-border e-commerce export overseas warehouse (applicable supervision code "9810").
（2） How to declare cross-border e-commerce export overseas warehouse (9810) to customs?
Answer: One is to declare through the H2018 customs clearance management system.
(1) Electronic information transmission. Before declaration, cross-border e-commerce enterprises should transmit overseas warehouse booking information to customs.
(2) Declaration of customs declaration form. Cross border e-commerce enterprises or their agents declare customs declaration forms to the customs, and those that pass the system verification will be pushed to H2018.
The second is to declare through the unified version of the cross-border e-commerce export system.
(1) Electronic information transmission. Before declaration, cross-border e-commerce enterprises and logistics enterprises should respectively transmit overseas warehouse booking information and logistics information to the customs.
(2) List declaration. Cross border e-commerce enterprises or their agents shall declare the list to the customs, and the list that has been verified by the system shall be pushed to the unified version of the cross-border e-commerce export system. The list does not need to be summarized and declared as a customs declaration.
Enterprises should submit declaration data and transmit electronic information to customs through the international trade "single window" or "customs government service integration platform", and bear corresponding legal responsibilities for the authenticity of the data.
（3） What customs clearance convenience does the new policy for cross-border e-commerce export of overseas warehouses bring to enterprises?
Answer: One is the informatization of the entire customs declaration process. Enterprises transmit electronic information such as transaction orders and overseas warehouse booking receipts through the internet, all of which are automatically imported in standard message formats. The paperless customs declaration forms and declaration lists effectively simplify the declaration procedures.
The second is to add a convenient declaration channel. In response to the low value and large volume of export invoices for small and medium-sized enterprises, a more convenient declaration channel has been provided, streamlining the transmission of documents and declaration items, further reducing the cost of customs clearance for enterprises and improving clearance efficiency.
The third is to simplify the application process in the comprehensive pilot zone. Referring to the simplified declaration method for general export of cross-border e-commerce retail (9610) carried out by the customs in the location of the comprehensive pilot zone for cross-border e-commerce, the list of eligible overseas warehouses for cross-border e-commerce export (9810) declared by the customs in the location of the comprehensive pilot zone can be applied for simplified declaration according to a 6-digit HS code.
The fourth is the convenience of logistics and inspection. Cross border e-commerce exports overseas warehouse goods that are suitable for both national customs clearance integration and transit mode. Enterprises can choose a more efficient and optimal way to transport goods according to their actual situation, while enjoying the convenience of priority inspection.
（4） Is it still necessary to register the overseas warehouse business model with customs for cross-border e-commerce export overseas warehouse (9810) business?
Answer: According to the Announcement of the General Administration of Customs on Further Promoting the Development of Cross border E-commerce Exports (Announcement No. 167 of the General Administration of Customs in 2024), enterprises engaged in cross-border e-commerce export overseas warehouse business do not need to register the export overseas warehouse business model with the customs, and will no longer comply with the requirement of "should register the export overseas warehouse business model with the customs" in Announcement No. 75 of the General Administration of Customs in 2020. Enterprises still need to transmit electronic data of warehouse receipts to customs during the declaration process and are responsible for their authenticity.
（5） What are the preferential policies for the cross-border e-commerce export overseas warehouse (9810) model?
Answer: Customs implements customs clearance supervision on cross-border e-commerce export overseas warehouses (9810) in accordance with the law, confirms the actual departure status of goods, and actively implements the "Announcement of the State Administration of Taxation on Supporting the Development of Export Tax Refunds (Exemptions) for Cross border E-commerce Export Overseas Warehouses" (Announcement No. 3 of the State Administration of Taxation in 2025), which means that taxpayers can apply for export tax refunds (exemptions) for goods exported in the cross-border e-commerce export overseas warehouse mode (9810) after the goods are declared for departure. When taxpayers apply for export tax refund (exemption), if the goods have already been sold, they shall apply for export tax refund (exemption) in accordance with current regulations; For goods that have not yet been sold, export tax refund (exemption) can be declared and processed according to the method of "tax refund upon departure and re accounting of sales". That is, after the goods are declared for departure, export tax refund (exemption) can be pre declared and processed (hereinafter referred to as "export pre tax refund"), and subsequent tax accounting can be carried out based on the sales situation of the goods.
（6） What tax benefits can cross-border e-commerce export overseas warehouses (9810) enjoy if their goods are returned to the country due to unsold goods?
Answer: According to the Announcement of the Ministry of Finance, the General Administration of Customs, and the State Administration of Taxation on Tax Preferential Policies for Cross border E-commerce Export Returned Goods (Announcement No. 16 of 2026 by the Ministry of Finance, the General Administration of Customs, and the State Administration of Taxation), goods (excluding food) declared for export under the 9810 code from January 1, 2026 to December 31, 2027 and returned to the country in their original state due to unsold or returned goods within 6 months from the date of export are exempt from import tariffs, import value-added tax, and consumption tax; The export tariffs already collected at the time of export are allowed to be refunded. Enterprises that have already processed export tax refunds shall make up for the refunded taxes in accordance with current regulations. Enterprises should apply for exemption from import tariffs, import value-added tax, and consumption tax, and refund of export tariffs, based on the "Certificate of Supplementary Tax Payment/Non Refund of Export Goods" issued by the competent tax authority.

2、 Regarding Market Procurement and Trade

（1） What is the market procurement trade method?
Answer: Market procurement trade refers to the trade method of purchasing goods in a recognized market cluster area, with a maximum value limit of 150000 US dollars on a single customs declaration form. Qualified operators handle export clearance procedures with the customs at the place of purchase.
The overall process of engaging in market procurement is subject filing → transaction registration → packing of goods → submission of customs declaration → export declaration → completion of transaction and foreign exchange settlement.
（2） What are the requirements for exporting goods through market procurement trade?
Answer: The value of the goods on a single customs declaration is less than or equal to 150000 US dollars. The following goods are not eligible for market procurement trade: goods prohibited or restricted from export by the state; Goods that have not been confirmed by the market procurement commodity identification system; Other goods that are not suitable for market procurement trade as determined by the trade control authority.
（3） How to simplify declaration in market procurement trade?
Answer: "Simplified declaration" is the main convenience measure in the customs clearance process, which refers to the consolidation and classification declaration of some goods exported through market procurement trade in accordance with relevant regulations during the customs declaration process.
For each customs declaration form corresponding to more than 5 types of goods listed in the goods list, simplified declaration can be implemented in the following way: firstly, the top 5 goods with the highest value should be declared item by item on the export customs declaration form from high to low value, and the filling of the customs declaration form should comply with the requirements of the "Customs Import and Export Goods Declaration Form Filling Specification of the People's Republic of China"; The second is to merge other goods based on the "seal" unit in the "Import and Export Tariff of the People's Republic of China". Each "seal" is merged according to the tax number of the commodity with the highest value as the merged tax number, and the value, quantity, etc. are also merged accordingly.
In addition, it should be noted that simplified declaration is not applicable to goods that fall under any of the following circumstances, including: those that require export tariffs; Those that require inspection and quarantine; Customs regulations do not apply to simplified declaration. When deemed necessary, the on-site customs may request the enterprise to provide a list of goods in the market comprehensive management system, and the enterprise should also prepare in advance.

3、 Regarding bonded maintenance, testing, and remanufacturing

（1） Which products are eligible for bonded maintenance?
Answer: Enterprises within the comprehensive bonded zone must carry out bonded maintenance within the scope of the maintenance product catalog issued by the Ministry of Commerce and other three departments. At present, four batches of catalogs have been issued, including 276 categories of products such as integrated circuits, drones, AR glasses, and automotive power batteries. In addition, the General Administration of Customs' "Several Measures to Promote Capacity Expansion and Quality Improvement of Comprehensive Bonded Zones" (hereinafter referred to as the "New Policy") allows domestically processed and manufactured export products and their spare parts to enter the comprehensive bonded zone from overseas for maintenance and then be transported out of the country, without being restricted by the comprehensive bonded zone maintenance product catalog and the prohibited import of old mechanical and electrical products catalog. It allows finished products that have completed bonded maintenance in the comprehensive bonded zone to be used for direct export processing and production within the zone.
（2） How to declare and supervise bonded maintenance goods?
Answer: If the goods to be repaired are transported from overseas into the area for repair and then transported out of the area after repair, the enterprises in the area should fill in the bonded repair (code 1371). If the goods to be repaired come from within the country (outside the region), enterprises outside the region should fill in "repair items (code 1300)", and enterprises within the region should fill in "bonded maintenance (code 1371)"; Repaired goods shall be transported back to the domestic area (outside the region). Enterprises outside the region shall fill in "repaired items (code 1300)", while enterprises within the region shall fill in "bonded maintenance (code 1371)". Repaired goods and maintenance costs shall be separately reported as commodity items. In principle, all goods to be repaired, repaired goods, and replaced old or damaged parts should be re shipped out of the country. If it is indeed impossible to transport it out of the country, it shall not be sold domestically and shall be destroyed and disposed of according to regulations. Solid waste generated during maintenance must be disposed of by qualified units.
（3） What support measures does the country have for the pilot of new bonded testing formats?
Answer: The new policy encourages enterprises in the area to carry out high-tech and high value-added bonded testing business. Consumable materials imported for testing can be verified based on actual testing consumption. Explore the implementation of positive list management for bonded inspection, support the export products and their spare parts processed and manufactured domestically to enter the comprehensive bonded zone for inspection from overseas, and not be restricted by the catalog of prohibited imported old mechanical and electrical products.
（4） Is bonded remanufacturing subject to restrictions on the import of used goods?
Answer: Currently, the new form of bonded remanufacturing is being piloted on a case by case basis in comprehensive bonded zones such as Shanghai, Chongqing, Tianjin, and Guangxi. The new policy supports enterprises within the zone to carry out international logistics distribution business for overseas remanufactured products with both ends outside. Relevant products entering the comprehensive bonded zone from overseas are not subject to China's measures prohibiting or restricting the import of used goods.