2026 Key Practical Tips for Compliant Export Tax Refund Declaration Process

2026 Key Policy Changes and Practical Tips for Export Tax Refund

In 2026,customs policies of major global trading countries have adjusted frequently,and China Customs has also updated the HS code classification rules and tax refund rate tables.Foreign trade enterprises need to follow policy changes in a timely manner to avoid tax refund losses caused by rate mismatches.In March 2026,the Ministry of Finance and the General Administration of Customs jointly issued Announcement No.12,adjusting the export tax refund rates of 127 categories of mechanical and electrical products and chemical products,among which the tax refund rate for new energy equipment was raised to 13%,and the rates for some high-energy-consuming chemical products were reduced to 9%.

1.Practical Responses to Adjustments in Tax Refund Rates

The key practical point here is that HS code must fully match the actual goods.A mechanical and electrical enterprise in 2025 misclassified PV inverters as general inverters,resulting in under-declaration of the tax refund rate by 4 percentage points and a loss of nearly two million yuan in tax refunds.In 2026,Customs’ big data comparison system has been upgraded,which can real-time compare the enterprise’s declaration data with the parameters of actual exported goods,including material,model,function,etc.Any inconsistency may trigger a control inspection.

In response to tax refund rate adjustments,enterprises need to complete three actions: First,update their own HS code library and synchronize it with the customs declaration system; Second,check the factory inspection reports and HS code declaration elements of each batch of exported goods; Third,confirm the pre-classification channel at the port with the freight forwarder in advance to avoid on-site classification disputes.

2.Linkage Requirements between Certificate of Origin and Tax Refund

In 2026,the requirements for endorsing certificates of origin of RCEP member countries are more stringent.If exporting to member countries such as Japan and South Korea,failure to correctly fill in the "direct transportation clause" of the certificate of origin will result in ineligibility for the agreement tax rate and affect the documentary compliance of export tax refunds.Some ports require that the issuance date of the certificate of origin must be earlier than the declaration date of the customs declaration,and the transportation route must be consistent with the documents; otherwise,Customs will not recognize it.

In practice,enterprises need to complete the pre-audit of the certificate of origin 3 days before the goods are shipped.They can submit applications through the single window of the China Council for the Promotion of International Trade to avoid port detention caused by port inspections.The newly added electronic endorsement function in 2026 realizes online verification of certificates of origin,greatly shortening the audit time,but requires prior enterprise registration.

3.New Regulations on Foreign Exchange Settlement and Tax Refund Verification and Write-off

In 2026,the State Administration of Foreign Exchange has updated the declaration requirements of the foreign exchange monitoring system for trade in goods.Enterprises need to complete the foreign exchange receipt declaration within 15 days after the goods are exported; otherwise,they will not be able to complete tax refund verification and write-off.In case of delayed foreign exchange receipt,they need to submit an extension application to the foreign exchange administration in advance; otherwise,they will be included in the foreign exchange control list,affecting subsequent tax refund business.

Some enterprises have the practice of collecting foreign exchange through third parties.In 2026,Customs requires enterprises collecting foreign exchange on behalf of others to provide a power of attorney for foreign exchange collection,and the amount of foreign exchange collected on behalf of others must be consistent with the amount on the customs declaration; otherwise,it will be recognized as exchange loss risk,and the tax refund application will be rejected.

Risk Early Warning and Pitfall Avoidance Guide for Export Tax Refunds

In 2026,Customs’ control inspection rate has increased to 18%.Common tax refund risk points include:

• Inconsistency between declaration elements and actual goods: For example,failure to mark product model,material or brand,leading Customs to question that the goods category is inconsistent with the declaration
• Regional risk of off-site declaration: When declaring at a non-local port,enterprises need to complete off-site filing with the electronic port in advance; otherwise,they cannot receive the tax refund receipt
• Inconsistency between documents: The information of customs declaration,invoice,packing list and certificate of origin is not fully matched,such as inconsistency in quantity,weight and value
• Failure to declare anti-dumping duty in advance: When exporting to countries with anti-dumping duties such as Europe and the United States,failure to indicate the amount of anti-dumping duty on the customs declaration leads to deduction of corresponding amounts during tax refund

In 2025,a foreign trade enterprise in Shenzhen exported hardware tools to the European Union.Due to failure to complete off-site filing with the electronic port,the application was rejected when declaring at Shanghai Port.The detention fee amounted to more than 30,000 yuan,and the arrival of tax refunds was delayed,affecting the enterprise’s capital turnover.

Practical Solutions for Cross-Region Export Tax Refunds

As a foreign trade agency at Shanghai Port,Zhongshitong can provide off-site declaration services for ports nationwide.Core advantages include networked declaration for ports nationwide,eliminating the need for enterprises to travel between local Customs; global trade compliance risk control,pre-judging anti-dumping duty policies of destination countries; one-stop foreign exchange settlement and tax refund verification and write-off,shortening the capital recovery cycle to 7 working days.

Practical Case: Tax Refund Recovery Solution for a Mechanical and Electrical Enterprise

Scenario: In May 2026,a mechanical and electrical enterprise in Shenzhen exported 120 PV inverters to Australia.Due to incorrect HS code classification,it was controlled and inspected by Shanghai Customs,and the tax refund application was rejected.The original declared HS code of the enterprise was 85044099,corresponding to a tax refund rate of 9%,but the actual product was a PV inverter with MPPT function,and the correct HS code was 85044011,corresponding to a tax refund rate of 13%.

Task: Assist the enterprise in reclassifying the HS code,completing the tax refund declaration and rectification for Customs inspection.

Action: Retrieve the factory inspection report of this batch of products and the certification requirements of the Australian importer,contact the Customs Classification Department to complete pre-audit,adjust the HS code to 85044011,supplement and provide CE certification documents,complete off-site declaration filing with the electronic port,and assist the enterprise in submitting a rectification statement to Customs.

Result: Customs review was completed within 3 working days,and the full tax refund amount of 1.87 million yuan arrived.Detention losses and tax refund delays were avoided,and the enterprise subsequently entrusted all its export tax refund business to this agency.

2026 Special Requirements for Export Tax Refunds in European and American Markets

For goods exported to the United States,attention should be paid to the tax refund restrictions of the Inflation Reduction Act on new energy products.If the products do not meet the local content requirements,they will not be eligible for US tax refund policies,and will also affect China’s export tax refunds.For the European Union market,attention should be paid to the Carbon Border Adjustment Mechanism (CBAM) requirements on product carbon emissions.Enterprises need to provide carbon emission test reports; otherwise,carbon tariffs will be imposed,affecting the compliance of export tax refunds.

In 2026,the European Union added anti-dumping duties on Chinese hardware tools,with a tax rate of 15%-25%.Enterprises need to indicate the amount of anti-dumping duty on the customs declaration; otherwise,Customs will deduct the corresponding amount,affecting the tax refund audit progress.

The core of export tax refund is document consistency,that is,the information of all documents must be fully matched,including customs declaration,invoice,packing list,certificate of origin,foreign exchange receipt voucher,etc.Enterprises need to strengthen internal document review,or entrust a professional agency to complete compliant declaration,to avoid large tax refund losses due to small mistakes.