Is the Amount on Export Customs Declaration Form Tax-Inclusive? 2026 Updated Interpretation

Essence of Customs Declaration Amount: Is It Tax-Inclusive?

The core dispute over the amount on customs declaration forms at Shanghai Port in 2026 lies in "whether the amount includes tax".It should be clarified that the amount indicated on the customs declaration form is the tax-exclusive price under trade terms such as Free on Board (FOB) or Ex Works (EXW),rather than the total price including value-added tax.Customs declaration follows the Customs Law and the Catalogue of Standardized Declaration for Import and Export Commodities,only taking "goods value" (i.e.the value of the commodity itself) as the tax calculation base,and does not directly reflect the tax amount.

Distinction Logic Between Customs Duty and Value-Added Tax

• Customs duty calculation: Only based on the customs declaration amount (FOB),calculated according to the tax rate corresponding to the commodity HS code,irrelevant to value-added tax
• Value-added tax: For general trade exports,the value-added tax invoice amount must be consistent with the customs declaration goods value (FOB),and additional "exemption,credit and refund" data shall be declared
• Special case: Under the newly added 9610 cross-border e-commerce mode in 2026,the customs declaration amount includes comprehensive cross-border e-commerce tax (i.e.customs duty + value-added tax),which shall be marked separately

Differences in Amount Composition Under Different Trade Terms

Among export enterprises represented by Shanghai Zhongshitong,common trade terms include FOB,CIF,EXW,DAP,etc.The "tax inclusion attribute" of customs declaration amount under different terms is handled completely differently:

Linkage Logic Between Export Tax Rebate and Customs Declaration Amount

The customs declaration amount directly determines the calculation base of export tax rebate.The export tax rebate rate has been adjusted to the range of 13%-17% in 2026,but two core conditions must be met:

• The customs declaration amount (FOB) and the value-added tax special invoice amount must correspond "one invoice for one shipment",and there shall be no difference between the tax invoice and the customs declaration amount caused by "over declaration/under declaration"
• If the customs declaration amount includes "domestic freight/insurance premium",the "freight,insurance and commission" amount shall be noted separately,otherwise it may be deemed as "false declaration" and trigger customs inspection

2026 Tax Rebate Practical Operation Pitfall Avoidance Guide

Case S-T-A-R: A Shanghai hardware enterprise declared an export amount of 1 million US dollars in January 2026.It mistakenly took the value-added tax invoice amount (total price and tax of 1.13 million RMB) as the customs declaration amount,resulting in matching failure of the tax rebate system.Correct operation: The customs declaration amount shall be declared at the tax-exclusive price of 800,000 RMB (1,000,000 / 1.13),and the value-added tax invoice shall be issued separately with 800,000 RMB tax-exclusive amount + 104,000 RMB tax amount,to ensure that the tax rebate amount (800,000 RMB × 13% rebate rate) = 104,000 RMB.

2026 Export Customs Declaration Practical Operation Risks and Responses

Three major risks of customs declaration amount declaration at Shanghai Port:

1.Amount Mismatch Caused by Exchange Rate Fluctuation

• Risk point: The customs declaration amount is converted according to the exchange rate on the declaration date (USD/CNY fluctuates in the range of 6.7-7.3 in 2026).If the exchange rate is not updated in time,the deviation between the foreign exchange receipt amount and the customs declaration value may exceed 5%
• Response: Enterprises represented by Zhongshitong use the "spot settlement exchange rate locking service" to complete exchange rate filing on the General Administration of Customs "Single Window" 3 days in advance

2.Conflict Between Destination Country Tariff and Declaration Amount

• Risk point: The EU updated the anti-dumping duty list in 2026.If the customs declaration amount is lower than the actual transaction price,it may be deemed as "low-price dumping" and trigger inspection for 5-15 days
• Response: It is recommended to submit the "third-party valuation report" (issued by institutions such as SGS) simultaneously to prove the rationality of the declared amount

3.Exchange Loss and Safe Boundary of Declaration Amount

• Risk point: If the foreign exchange receipt amount is more than 10% lower than the customs declaration amount,it may be marked as "abnormal foreign exchange receipt" by the State Administration of Foreign Exchange,and the account will be frozen for 30 days
• Response: Adopt the mode of "batch settlement + difference verification and cancellation",split the amount into less than 3 small repayments,and control the amount difference of each transaction within 5%

Zhongshitong National Port Service Advantages and 2026 Special Scheme

Relying on the Shanghai headquarters and 12 directly affiliated port branches across the country,the following services can be provided in 2026:

• Cross-regional off-site declaration: For transit transportation at Ningbo Port,Shenzhen Port,Guangzhou Port,etc.the customs declaration amount is automatically synchronized to the local customs,avoiding regional policy differences
• Global price checking system: Real-time capture of tariff databases of major trading countries in 2026,automatically matching the optimal HS code (for example,a mechanical part is switched from HS84860000 to 84863000,and the tax rebate rate is increased by 2 percentage points)
• Dynamic tax rebate rate early warning: Push the next month’s export tax rebate rate adjustment list before the 15th of each month to help enterprises lock in the optimal scheme in advance

Export enterprises in 2026 should be clearly aware that the essence of whether the customs declaration amount is tax-inclusive is the balance between "trade compliance red line" and "maximization of tax rebate benefits".Shanghai Zhongshitong suggests that before declaring the customs declaration amount,be sure to check the tax rebate rate corresponding to the product HS code (the tax rebate rate of some chemical products was reduced from 9% to 5% in 2026),and complete the pre-examination through the "Single Window" to avoid fines of 50,000 to 100,000 RMB and tax rebate delay of 1 to 2 months caused by wrong amount.