2026 Practical Operation of FOB for Export Tax Refund, Help You Accurately Obtain Tax Refund Funds

Core Policies and Practical Logic of FOB for Export Tax Refund in 2026

The export tax refund management measures updated by the General Administration of Customs in 2026 explicitly specify FOB as the sole legal basis for export tax refund calculation,replacing the previous CIF price conversion model allowed in some regions.This adjustment directly affects the calculation of enterprises’ tax refund base,and further determines the amount and timeliness of tax refund arrival.Many foreign trade enterprises have their declarations rejected,tax refunds delayed or even suffer capital losses due to inadequate understanding of policy details.

Two Core Changes in 2026 Policy Adjustment

• Binding of certificate of origin and FOB declaration: For member countries of free trade agreements such as RCEP and ASEAN,enterprises are required to submit corresponding certificates of origin,and the FOB indicated on the certificate must be completely consistent with that on the customs declaration form and commercial invoice,otherwise they cannot enjoy preferential agreement tax rates.
• Enhanced three-document consistency verification: The customs will cross-check FOB data on customs declaration forms,commercial invoices and ocean bills of lading,and any minor discrepancy may trigger targeted inspection.

Common Practical Risks of FOB for Export Tax Refund and Avoidance Suggestions

We have handled a large number of tax refund disputes caused by incorrect FOB declaration,among which the most typical case is from a hardware tool exporter based in Shanghai: In 2025,the enterprise exported 1,200 sets of wrenches to Germany.It mistakenly included domestic freight in FOB during customs declaration,making the declared amount 4.2% higher than the actual FOB value.It was placed under targeted inspection by Ningbo Customs,which delayed the tax refund by 37 days and incurred a late fee of approximately CNY 23,000.Later,with our assistance,it reorganized the documents and submitted compliance explanations,and the supplementary approval of tax refund was completed within 3 working days.

• Risk 1: Price calculation deviation: Including non-FOB link costs such as domestic freight,insurance premiums and commissions into the declaration base,resulting in overstated or understated tax refund amount.
• Risk 2: Invalid document matching: Inconsistent FOB data among certificate of origin,customs declaration form and invoice,especially for Form E certificates for RCEP member countries,incorrect filling will directly affect the application of agreement tax rates.
• Risk 3: Non-compliant exchange rate selection: Failing to adopt the RMB central parity rate published by the State Administration of Foreign Exchange on the declaration date,but choosing the settlement rate independently,leading to incorrect tax calculation base.
• Risk 4: Destination tariff linkage error: Failing to consider adjustments of anti-dumping duties and additional duties of the importing country,including amounts covering additional tariffs into FOB declaration,which will raise doubts from the destination customs.

In response to these risks,we have summarized directly implementable avoidance actions: First,complete FOB calculation 3 days before shipment,and the finance and taxation team shall check payment vouchers for freight and insurance premiums; Second,complete cross-check of three-document data before declaration to ensure that the prices on all documents are completely consistent; Finally,check the latest 2026 tariff policies of the destination country in advance to avoid inconsistency between declared price and actual tax burden.

Zhongshitong’s Full-process Agency Service Support

As a foreign trade agency headquartered in Shanghai,we rely on the resource advantages of Shanghai as an international trade center to provide FOB declaration services for export tax refund covering ports across the country:

• Accurate HS code classification: Reviewed by a professional team with more than 12 years of classification experience to ensure that the code fully matches the material and function of actual goods,and avoid incorrect tax rate application.
• Compliant FOB calculation: The professional finance and taxation team accurately excludes all non-FOB link costs in accordance with FOB terms to ensure the legality and compliance of the tax calculation base.
• Document review and inspection prediction: Compare all data of customs declaration forms,invoices,bills of lading and certificates of origin in advance,predict the risk of customs targeted inspection and prepare explanatory materials in advance.
• Linked declaration at national ports: Covering 12 core ports including Shanghai,Ningbo,Shenzhen and Qingdao,enterprises can complete cross-regional customs declaration and tax refund declaration without traveling across regions.

2026 Compliance Self-inspection Checklist for FOB of Export Tax Refund

Global trade rules continue to adjust in 2026.For example,the EU’s Carbon Border Adjustment Mechanism (CBAM) has been officially included in the review scope of export tax refunds.Enterprises need to consider carbon cost calculation synchronously when declaring FOB.We suggest that foreign trade enterprises cooperate with professional agency institutions in advance to avoid compliance risks caused by missing policy details.