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Interpretation of preferential tax policies for returned goods by cross-border e-commerce

财政部、海关总署、国家税务总局联合发布2026年第16号公告,为跨境电商出口退运商品量身打造税收优惠政策。本文全面解读该政策,包括出台背景、适用条件、优惠内容、申报材料及重点难点问题等,助力企业用足政策红利。

Cross-border export goods are sold overseas, but have to be returned to China due to unsalable or after-sales reasons. High tariffs, value-added tax, and consumption tax between entry and exit put enterprises in a dilemma.
The Ministry of Finance, the General Administration of Customs, and the State Administration of Taxation recently jointly issued Announcement No. 16 of 2026, creating a set of preferential tax policies for cross-border e-commerce export return goods.
Below we will fully interpret this document to help you clarify the key points of the policy and make full use of the policy dividends.

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Background of the introduction of the policy: “Relaxing ties and reducing burdens” for new cross-border e-commerce formats

Cross-border e-commerce, as the core force of my country’s new foreign trade formats, has continued to maintain a rapid growth trend in recent years, and the scale of exports has continued to expand.
Relying on my country’s complete manufacturing system and strong supply chain advantages, cross-border e-commerce export products have covered multiple categories such as electronics and digital products, clothing and accessories, and home furnishings.
However, cross-border exports are not always smooth sailing.
Affected by various factors such as demand fluctuations in overseas markets, logistics delays, and insufficient product adaptability, returned shipments are inevitable.

In the past, returning goods had to pay import duties, value-added tax and consumption tax according to regular procedures in order to re-enter the domestic market. Coupled with cumbersome customs clearance procedures, the cost of return shipping was high.
Some companies are even forced to directly destroy overseas returned goods due to high return shipping costs, resulting in a waste of resources and huge economic losses.
Therefore, the three departments jointly issued Announcement No. 16 to create a convenient and low-cost return channel for export returned goods, accurately targeting the pain points of the industry. The purpose is to reduce the return costs of enterprises, reduce their worries, and actively support the development of new foreign trade formats.

Which products can enjoy this preferential policy?
Five major conditions are indispensable

The core content and guidance of Announcement No. 16 is “precise burden reduction and standardized supervision”. Discounts are only provided for cross-border e-commerce export returned goods in specific scenarios and specific scopes. Not all returned goods are eligible.
To enjoy this policy, an enterprise must meet the following five conditions:

First, time condition.
During the period from January 1, 2026 to December 31, 2027, goods declared for export under the cross-border e-commerce customs supervision code.
Cross-border e-commerce customs supervision codes include four categories: 1210, which is bonded cross-border trade e-commerce, 9610, which is cross-border e-commerce retail export, 9710, which is cross-border e-commerce B2B direct export, and 9810, which is cross-border e-commerce export overseas warehouse.

It should be noted that although Announcement No. 16 was issued on February 6, 2026, the policy effectiveness can be traced back to January 1, 2026.
In other words, cross-border e-commerce companies that have returned goods and paid taxes before the announcement can apply to the customs for tax refunds and re-apply related tax incentives based on this announcement.

Second, return time limit conditions.
Return the goods into the country in their original condition within 6 months from the date of export.
It is worth noting that the policy specifically stipulates special circumstances under item 1210: the goods should be returned to outside the domestic area within 6 months from the date of departure from the special customs supervision area or bonded logistics center, not the time when the 1210 exit is first declared in the customs system.

Third, return conditions in original condition.
The minimum form of the goods when returned to the country should be basically the same as the original form when exported. No accessories or parts may be added, and no processing or modification shall be performed.
However, the announcement pointed out that changes in logistics operations necessary for unpacking, inspection, installation, and commissioning can still be regarded as “original status.”

Fourth, unused requirements.
In principle, the returned imported goods should be unused, but if the poor quality can only be found through trial or it can be proven that they are genuine defective goods returned by customers after trial, they are not subject to this prohibition and are deemed to meet the “original condition” requirement.

Fifth, it does not contain food.
Regardless of the reason for return, food cross-border e-commerce export products must go through tax payment procedures according to regular procedures and cannot enjoy preferential policies.

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What are the specific discounts?
Burden reduction, tariff refund, and tax refund

Cross-border e-commerce export and return goods that meet all the above five conditions can enjoy the following three levels of discounts:

First, exemption from import tariffs.
When the returned goods re-enter the domestic market, the import tariffs, value-added tax and consumption tax originally paid will be waived, significantly reducing the return costs for enterprises.

Second, refund export duties.
If the enterprise has paid export duties as required when the goods are exported, and the goods meet the return conditions stipulated in Announcement No. 16, the export duties collected will be refunded.

Third, pay back the export tax refund that has been processed.
This is the compliance point most commonly overlooked by businesses.
If an enterprise has already applied for export tax rebate when exporting, it must make up for the refunded tax in accordance with current regulations before applying for tax benefits on return shipments.
After the back payment is completed, with the “Certificate of Tax Paid/Not Refunded on Export Goods” issued by the competent tax authority, you can apply for exemption from import duties, import value-added tax, consumption tax, and refund of export duties.

What materials do companies need to prepare to declare return shipment?

Announcement No. 16 makes three distinctions in documentary materials for goods that enjoy preferential treatment to ensure smoother and legal declaration:

The first is basic materials.
Regardless of the reason for the return, the enterprise should submit an export commodity declaration list or export customs declaration, an explanation of the reason for the return, and other materials proving that the product is indeed returned to the country due to unsaleable or returned goods.

The second is unsalable returns.
Enterprises only need to submit a “self-declaration” and make a written commitment to return goods due to unsalable goods, which can be used to apply for return tax exemption and other procedures.

The third is return and shipping.
Enterprises should provide specific return records, including return records or rejection records on the platform, relevant return agreements, etc. as materials explaining the reasons for return shipments.

Examples of key and difficult issues

Difficulty point 1: How to calculate the “six-month period” under the cross-border e-commerce model?

For example: A company exported a batch of clothing under the cross-border e-commerce customs supervision code 9810 on April 1, 2026.
According to the policy, if the goods are returned to the country in their original condition within 6 months from April 1 due to unsalable or returned goods, that is, no later than October 1, 2026, they can enjoy the exemption of the three import taxes.

Here comes the key: If the company’s goods are exported through the 1210 bonded trade model, the export time point must be determined according to the special provisions of the announcement, “returning to the domestic and outside the zone within 6 months from the date of departure from the zone.”

Difficulty 2: After trial by overseas consumers, can I still enjoy the “return in original condition” discount?

For example: A cross-border e-commerce company exported a batch of clothing to the European market.
After the consumer purchased the product, he tried it on and found that the size was not suitable, so he returned the product in its original condition.
Although this batch of clothing has been worn by consumers when it is returned and imported, the policy has special exemptions for cases where the poor quality can only be discovered after a trial – it can be confirmed that it meets the requirements of “returning and entering the country in its original condition”.
On the other hand, if the product has been used by the consumer and is obviously damaged when it is returned, it will not be within the scope of the return shipping discount.

Difficulty 3: The export tax rebate has been processed when exporting, what should I do when the shipment is returned?

For example: A cross-border e-commerce company exported a batch of household appliances, and the company handled export tax rebates according to normal procedures when exporting.
Half a year later, due to changes in overseas market demand, some products became unsalable and needed to be returned to China for resale.
According to policy regulations, if an enterprise wants to enjoy the exemption of the three import taxes on returned shipments, it must first pay the refunded taxes to the tax authorities.
After the back payment is completed, the enterprise must obtain the “Certificate of Tax Paid/Non-Refunded on Export Goods” issued by the competent tax authority, and then use this certificate to apply to the customs for exemption from import duties, import value-added tax, consumption tax, and refund of export duties.
To put it simply, you don’t have to pay import taxes when you return it to the country, but you have to pay back the money you already pocketed when you exported it.

Difficulty 4: How to calculate the time for return of bonded goods under item 1210?

For example: A cross-border e-commerce company left the 1210 supervision warehouse in a comprehensive bonded zone in China on May 1, 2026 and shipped a batch of electronic products to Japan.
This batch of goods needs to be returned to the country due to slow sales.
Then, the enterprise must return the goods to the territory and outside the zone within 6 months from the date of departure from the zone, that is, no later than November 1, 2026, in order to enjoy the exemption of the three import taxes.
What is particularly confusing here is that the starting point is not the export declaration time, but the date when the goods actually leave the bonded area.

Summary

The core content of Announcement No. 16 of 2026 can be summarized as follows: the three departments have jointly worked to build a cost berm for the retreat of cross-border e-commerce.
The implementation period is from January 1, 2026 to December 31, 2027, covering the four main regulatory codes of cross-border e-commerce. The preferential treatment covers the exemption of three taxes on imports and the refund of export duties. However, the hard threshold of “within 6 months from the date of export” and “returning into the country in its original condition due to unsalable returns” must be strictly adhered to. At the same time, it is clear that food will be excluded.
If a tax refund has been applied for when exporting, the tax must be paid first before enjoying the benefits.
It is recommended that cross-border e-commerce companies investigate existing return shipping needs as soon as possible, prepare key materials such as the “Certificate of Tax Paid/Non-Refunded for Export Goods” and return records, and promptly use policy dividends to not only reduce compliance risks but also minimize return shipping costs.

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