I. Tax Rate Determination
What determines the tax rate?
Based on export tariff practices, the conclusions are as follows: **Export Tax Rate**—Export tax rates are established for export goods (provisional rates may apply for specific periods; Article 10 of the Tariff Law); **Non-levy**—No export tax is levied on goods for which no export tax rate is specified in the Customs Import and Export Tariff schedule (Article 7 of the State Council Regulations on Import and Export Tariffs); **Mechanical Parts**—For commodity code 8431499000 (other parts for headings 8426, 8429, and 8430, excluding specifically listed parts), the rates are: MFN rate 0.05000, general rate 0.17000, export rate 0.00000, VAT rate 0.17000, consumption tax rate 0.00000, and unit of measurement in kilograms (General Administration of Customs commodity rate inquiry); **General Application**—For non-standard assembly lines classified as complete sets of mechanical equipment, a zero export tax rate generally applies to their core components (verified via Customs commodity rate inquiries and item-by-item checks against commodity codes); **Complete Sets**—For complete sets of equipment, the export tax rate is verified after determining the commodity code through tariff classification (mechanical equipment and parts mostly carry a zero rate in the current export tariff schedule; General Administration of Customs); **Provisional Rates**—The Customs Tariff Commission of the State Council may propose adjustments to tariff headings and applicable rules (implemented upon approval and promulgation by the State Council; Tariff Law); **Verification**—The specific export tax is determined by the Customs Import and Export Tariff schedule in effect at the time of declaration (import and export goods are subject to the tax rates in effect on the date the consignor/consignee or their agent declares the import or export; Tariff Regulations). In summary, there are six key aspects to consider regarding tax rates: the setting of export rates, non-levy for unspecified items, zero rates for mechanical parts, classification of complete sets, provisional rates, and application based on the declaration date.
Understanding these six points clarifies the tax rate situation.
II. Taxable Value
What to consider regarding taxable value.
Based on export tariff assessment practices, the price is determined as follows: **Basis**—The taxable value of export goods is determined based on the transaction price plus transportation, related charges, and insurance premiums incurred prior to the loading of the goods at the point of exit from the People’s Republic of China (Article 29 of the Tariff Law); **Transaction Price**—The transaction price of export goods refers to the total amount of payment (both direct and indirect) that the seller is entitled to receive from the buyer for the export of said goods (Tariff Law); **Exclusion**—Export duties are not included in the taxable value (Tariff Law); **FOB Basis**—The dutiable value of export goods is the FOB price (price upon sale to an overseas buyer) as verified by Customs, minus the export duty (Regulations on Import and Export Duties); **Verification**—Customs verifies and determines the dutiable value based on the transaction price plus transportation, related charges, and insurance premiums incurred prior to loading at the point of exit (Article 26 of the Regulations on Import and Export Duties); **Adjustments**—A dutiable value based on the transaction price must include transportation, related charges, and insurance premiums incurred prior to loading at the point of exit, but must exclude export duties and any transportation or related charges incurred *after* loading at the point of exit that are separately itemized in the price of the goods. **Summary of Price Determination (Six Key Points):** Transaction price plus pre-loading costs; total payment received by the seller; exclusion of export duties; deduction of export duty from the FOB price; verification and determination by Customs; exclusion of post-loading costs.
Adhering to these six points ensures accurate pricing.
III. Valuation Methods
What to consider regarding valuation methods.
Based on export duty valuation practices, the methods are assessed as follows: Undeterminable—where the transaction value of the exported goods cannot be determined, Customs determines the value sequentially (pursuant to Article 30 of the Tariff Law) after gathering relevant information and consulting with the taxpayer on the price; Identical—the transaction value of identical goods exported to the same country or region at the same or approximately the same time (Tariff Law); Similar—the transaction value of similar goods exported to the same country or region at the same or approximately the same time (Tariff Law); Cost—a price calculated based on the sum of the following: the cost of materials and parts, processing fees, customary profit and general expenses for producing identical or similar goods within the People’s Republic of China, as well as domestic transportation and related costs and insurance premiums (Tariff Law); Reasonable—a price determined using a reasonable method (Tariff Law); Consultation—valuation determined sequentially after Customs gathers relevant information and consults with the taxpayer on the price (Tariff Law). In summary, there are six bases for valuation: price consultation, identical goods, similar goods, the aggregate of cost and profit, reasonable methods, and sequential valuation;
each method is grounded in established rules.
IV. Value-Added Tax (VAT) Stage
What to consider regarding the VAT stage.
Regarding export VAT practices, consider these six aspects: **Exemption**—export-related VAT is waived at the export stage (with the corresponding input VAT used to offset VAT payable; any unoffset balance is refunded; Ministry of Finance & State Taxation Administration Announcement 2026); **Export Enterprises**—entities or individual industrial and commercial households that have completed industrial/commercial and tax registrations as well as foreign trade operator filings, and that export goods either directly or via agency (Ministry of Finance & State Taxation Administration Caishui [2012] No. 39); **Exemption, Credit, and Refund**—this method applies to manufacturing enterprises (export-related VAT is waived; corresponding input VAT offsets VAT payable, and any unoffset balance is refunded; Ministry of Finance & State Taxation Administration); **Exemption and Refund**—this method applies to foreign trade enterprises (export-related VAT is waived for goods and services exported by enterprises lacking production capacity, and corresponding input VAT is refunded; Guangdong Taxation Bureau); **Taxation**—export operations not eligible for VAT refund/exemption or VAT exemption policies are subject to VAT payment as prescribed (scope includes exports of goods for which the Ministry of Finance and State Taxation Administration, pursuant to State Council decisions, have explicitly cancelled export VAT refunds/exemptions; Guangxi Taxation Bureau); **Distinctions**—export-stage VAT and export tariffs are distinct tax categories (export tariffs are levied based on tariff schedules—often at a zero rate—whereas export VAT follows the “exemption, credit, and refund” or “exemption and refund” mechanisms; Ministry of Finance & State Taxation Administration). In summary, the six aspects are: export-stage exemption, definition of export enterprises, “exemption, credit, and refund,” “exemption and refund,” taxable scenarios, and tax type distinctions.
V.
Inquiry Channels
What to look for regarding inquiry channels.
Based on practical experience with export tariff inquiries, the process involves six key checks: System—General Administration of Customs (GAC) Commodity Tax Rate Inquiry System (query.customs.gov.cn; check minimum, general, and export tax rates, VAT, consumption tax, units of measurement, and regulatory conditions by commodity code); Tariff Schedule—The official GAC import/export tariff schedule serves as the legal basis for export duties (determine applicable rates via commodity code classification and tariff laws); Coding—For complete sets of non-standard assembly line equipment, the tariff classification code must first be determined (classify based on function, principle, and use; consult GAC commodity tax rate inquiry); Declaration—Duties are calculated based on the tax rates in effect on the date of declaration (Customs Tariff Regulations); Regulation—The regulatory conditions column indicates whether export licenses or permits are required (e.g., restricted or controlled goods must be declared in accordance with Announcement No. 77; consult GAC commodity tax rate inquiry); Changes—Tax rates may fluctuate with adjustments to tariff headings (the Customs Tariff Commission of the State Council proposes adjustments, which are implemented after State Council approval; Tariff Law).
In summary, a reliable inquiry covers these six aspects: the commodity tax rate inquiry system, the statutory tariff schedule, classification codes, the tax rate on the declaration date, regulatory conditions, and tariff heading adjustments.
Conclusion
To determine the export duties for non-standard assembly lines, consider these five dimensions: tax rates, price, valuation, VAT, and the inquiry process.
Tax Rates—Export duty rates are set for export goods (provisional rates may apply for specific periods); goods not listed in the Customs Import and Export Tariff schedule are exempt from export duty; export duty rates for machinery are generally zero (e.g., code 8431499000 for machinery parts has a rate of 0.00000); non-standard assembly line equipment is classified according to the tariff schedule to determine the applicable rate; duties are calculated based on the rate in effect on the date of declaration. Valuation—The dutiable value of export goods is based on the transaction price plus transport, related charges, and insurance costs incurred prior to loading at the domestic point of exit; the transaction price comprises the total direct and indirect payments received by the seller; export duty is excluded from the dutiable value; the dutiable value is determined by Customs based on the FOB price minus the export duty. Valuation Methods—If the transaction price cannot be determined, Customs consults with the taxpayer and applies valuation methods sequentially: transaction price of identical goods, transaction price of similar goods, a constructed value (sum of costs for materials, processing, profits, general expenses, domestic transport, and insurance for identical/similar goods produced domestically), or other reasonable methods. Value-Added Tax (VAT)—Exports are exempt from VAT at the export stage (input VAT is offset against payable VAT, with any un-offset balance refunded; the “Exemption, Credit, and Refund” method applies to manufacturing enterprises, while the “Exemption and Refund” method applies to foreign trade enterprises; goods ineligible for exemption/refund are subject to standard VAT); export duty and export VAT are distinct taxes and must not be conflated. Inquiries—Use the General Administration of Customs’ commodity tax rate inquiry system (query.customs.gov.cn) to look up export duty rates by commodity code (includes minimum rates, general rates, export duty rates, VAT rates, consumption tax rates, units of measurement, and regulatory conditions); first determine the tariff classification code, then verify the rate; pay attention to adjustments in tariff headings and regulatory conditions.
In line with industry practice, export tariffs can be summarized as follows: machinery parts mostly enjoy zero-rated status; no duty is levied where no rate is specified; the taxable value is based on the transaction price plus pre-loading costs; and the VAT “exemption, credit, and refund” policy applies.
Navigate these four points, and tariff issues are resolved.
