Is a Bill of Lading Required for Export Tax Refund? Detailed Explanation of 2026 Latest Supervision Requirements of Customs and Tax Authorities

Is a Bill of Lading Required for Export Tax Refund: 2026 Supervision Rules Clarified

In 2026,the State Taxation Administration,together with the General Administration of Customs,updated the Management Specification for Export Tax Refund Documents for Future Reference,clarifying that bills of lading (including ocean bills of lading,air waybills,railway waybills,multimodal transport waybills and other title documents) belong to the second category of documents for future reference.They are not required as declaration submission documents in all export scenarios,but under some high-risk trade modes,the bill of lading is the core voucher for tax refund verification,and missing it will directly lead to declaration rejection.

The requirements for bills of lading vary greatly under different trade modes.Enterprises can clarify their own obligations against the following table:

Tax Refund Risks Caused by Non-compliant Bills of Lading and Typical Cases

According to export tax refund verification data of Shanghai Port in the first quarter of 2026,17% of tax refund rejection and delayed refund cases are related to non-compliant bills of lading,which extends the average tax refund arrival cycle of enterprises by 47 days per case,with the highest tax supplementary amount exceeding 2 million yuan.In March 2026,a hardware tool export enterprise in Suzhou declared tax refund for orders exported to Germany under EXW terms.The consignor on the submitted bill of lading was filled in as the overseas purchaser,without marking the export enterprise’s goods ownership.The tax authority judged that the goods ownership transfer link was abnormal,and the 1.28 million yuan tax refund was suspended.The enterprise subsequently supplemented freight forwarder certificates,goods ownership transfer agreements and other materials,and took 21 days to complete the review and get the tax refund.

Common risks of non-compliant bills of lading include:

• The consignor on the bill of lading is inconsistent with the export declaration subject,which cannot prove that the export enterprise owns the goods ownership,directly triggers taxation as domestic sales,and imposes value-added tax at a maximum of 13% of the export value.
• If the discharge port on the bill of lading is inconsistent with the destination country on the customs declaration form,and reasonable transit certificate cannot be provided,it will be directly judged as false export,included in the tax refund dishonest list,and cannot enjoy the tax refund policy within 3 years.
• If the house bill of lading (HBL) issued by a freight forwarder not registered with the Ministry of Transport is used,and the qualification certificate of the freight forwarder and manifest information are not kept synchronously,it will not be recognized as a valid document during verification.

Practical Implementation Plans for Bills of Lading in Different Scenarios

For general trade export scenarios under FOB terms that do not require submission of bills of lading,enterprises only need to keep scanned copies of original bills of lading without additional operations,but it should be noted that the information on the bill of lading must be completely consistent with the goods name,quantity and specification on the customs declaration form to avoid information contradiction during spot check.If it belongs to the three scenarios where bills of lading must be submitted,namely EXW export,export to high-risk countries,and single tax refund amount exceeding 500,000 yuan,three preparations should be made in advance: first,when requiring the freight forwarder to issue the bill of lading,mark the export enterprise as the actual owner of the goods in the title remarks column; second,if multimodal transport is adopted,keep the waybill information of each section of transport synchronously to ensure the traceability of logistics track; third,check the difference between the sailing date on the bill of lading and the customs clearance date on the customs declaration form in advance,and prepare the situation explanation in advance if the difference exceeds 7 days.

The Shanghai headquarters of Zhongshitong,in conjunction with customs declaration teams of 17 ports across the country,can match customs manifest data with bill of lading information in advance,and check for inconsistencies in advance.Enterprises in other regions do not need to go to the port,and all document reviews are completed online.The global agency network can simultaneously verify the transportation information of overseas sections,so as to avoid tax refund obstruction caused by logistics information fault.For special trade modes such as EXW,standardized title description templates can be issued in advance to ensure that the bill of lading meets tax verification requirements,which can shorten the tax refund review cycle by more than 15 days on average.

Risk Warning and Pitfall Avoidance Suggestions

The 2026 new regulations clarify that all export tax refund documents for future reference,including scanned copies of original bills of lading,need to be kept for 5 years,and copies alone cannot be kept.Verifiable electronic versions or original documents need to be provided during tax spot checks,and enterprises that fail to keep them as required will directly have their tax refund applications rejected.Enterprises should avoid three common traps during operation: first,do not use bills of lading issued by unregistered freight forwarders to save document exchange fees.Such bills of lading are not recognized by the tax authority,but will lead to additional demurrage charges and verification costs; second,for exports under EXW terms,do not directly agree to overseas customers’ requirements to fill in the consignor as an overseas subject,and must retain the export enterprise’s title mark; third,be sure to check that all elements of the bill of lading are completely consistent with the customs declaration form before tax refund declaration.Even a letter difference in a model will trigger price review and control,and extend the tax refund cycle by 30 to 90 days.

If enterprises are not sure about the rules of bill of lading preparation and tax refund declaration,it is recommended to entrust a professional agency to conduct document pre-review in advance,so as to avoid large tax refund losses caused by small document errors.