2026 Export Tax Refund Conditions: A Complete Guide for Foreign Trade Enterprises' Compliance Declarations

In 2026,global trade compliance supervision has tightened again.Different from the relaxed declaration requirements in 2025,customs and tax authorities have jointly upgraded their control models.Enterprises will face risks such as withholding tax refunds and administrative penalties if they are not careful.

Four Core Compliance Conditions for Export Tax Refunds

1.Basic Qualifications and Cargo Attribute Conditions

This is the threshold for tax refund declarations,none of which can be missing:

• The enterprise has completed the filing registration as a foreign trade operator,and its tax rating is Class B or above (for 2026,enterprises with Class C or below require on-site verification)
• Declared goods are self-produced or purchased goods within the scope of value-added tax (VAT) and consumption tax collection
• Goods have completed customs declaration and departure,and have been recorded in export sales accounting entries
• Goods are not included in the national list of prohibited export or revoked tax refunds (in 2026,127 high-energy-consuming products were added to the revoked tax refunds list)

In 2025,a hardware enterprise in Suzhou declared cold-rolled steel plates that had been included in the revoked tax refunds list as tax refunds due to failure to update the prohibited tax refunds list in time,which was rejected by tax authorities,resulting in a loss of nearly RMB 80,000 in pre-declaration costs.Zhongshitong’s risk control team will sort out the latest tax refunds list for customers 15 days in advance to avoid such mistakes.

2.Core Requirements for Document Compliance

Document inconsistency is the core reason for 90% of tax refund failure cases.In 2026,customs and tax authorities have realized full network verification of document data,and any information mismatch will trigger control.

• Accurate HS Code Classification: The 2026 version of the Customs Tariff of Import and Export has adjusted 3,217 commodity codes.For example,the code of new energy energy storage batteries was adjusted from 85076000 to 85076010,and the control rate for incorrect classification increased by 42%
• Declared elements are completely consistent with actual goods,including brand,model,material,specification,packaging method,etc.Even a difference in carton packaging weight may be deemed as false declaration
• Legal and valid customs declaration forms,VAT special invoices,and export sales contracts,and invoice information must completely match the commodity name and quantity on the customs declaration form
• Foreign exchange has been received,or meets national tax exemption and verification conditions (such as materials for overseas engineering use)

In 2026,an electronic enterprise in Shanghai was placed under customs control due to declaring the brand of lithium batteries as "unknown",delaying the tax refund declaration by 21 days and incurring nearly RMB 30,000 in capital occupation costs.Zhongshitong’s document team will verify each declared element one by one to ensure complete consistency with actual goods.

3.Matching of Trade Terms and Declaration Deadlines

Different trade terms correspond to different tax refund declaration deadlines and required documents.In 2026,Shanghai Port piloted the "Trade Terms Automatic Verification" system,and enterprises with delayed declarations will be included in the key supervision list.Below are declaration requirements for common trade terms:

4.Compliance Requirements Added by 2026 New Regulations

This year,the state has introduced two new regulations on export tax refunds that directly affect declaration success rates:

• Certificates of Origin (CO) for RCEP member countries must be submitted in electronic signature version; paper certificates are no longer accepted,and customs will verify origin information with the ASEAN Secretariat online
• Enterprises filing tax refunds in other regions must complete filing at the port in advance.12 pilot ports including Shanghai and Shenzhen support cross-regional declarations nationwide,no need to return to registration place to handle
• Goods covered by anti-dumping duties and countervailing duties will no longer enjoy export tax refund policies

Common Tax Refund Risks and Pitfall Avoidance Guide

Combined with Zhongshitong’s practical data in 2026,here are the three most common pitfalls:

• False declaration of HS code: After the customs control system was upgraded in 2026,the inspection rate of such acts reached 100%.Once verified,enterprises will face a fine of 50% of goods value and suspension of tax refund qualifications for 1 to 3 years
• Insufficient foreign exchange retention period: According to the 2026 foreign exchange management new regulations,enterprises must retain foreign exchange receipt certificates for at least 180 days; otherwise,tax refund verification cannot be completed
• Fake agency-issued Certificates of Origin: Customs of RCEP member countries have realized real-time sharing of CO data.Forged certificates will be directly intercepted,and the enterprise will be included in the untrustworthy list

Last year,a foreign trade enterprise in Ningbo entrusted a third party to apply for a Certificate of Origin at a lower cost,which was seized by Shanghai Customs.Not only were tax refunds withheld,but also tax refund qualifications were suspended for 6 months,resulting in a loss of nearly RMB 200,000.Zhongshitong’s document team will follow the entire process of CO application and verification to ensure the authenticity of each certificate.

Compliant declaration of export tax refunds is not a simple process operation,but requires accurate grasp of policy changes,document details and supervision trends.Relying on the resource advantages of Shanghai Port,Zhongshitong provides enterprises with full-process tax refund agency services,from HS code classification and document review to cross-regional declarations,solving enterprises’ tax refund problems in one stop,ensuring tax refunds are received on time and in full.