2026 Practical Compliance Declaration Guide for Steel Export Enterprise Tax Refund

Breakdown of Core 2026 Steel Export Tax Refund Policies

In 2026,the Ministry of Finance and the General Administration of Customs jointly adjusted the export tax refund rates for some steel products,with core adjustments focused on high-energy-consuming semi-finished steel categories.The tax refund rate for basic steel products such as hot-rolled ordinary steel plates and seamless steel pipes remains at 13%,while the rate for deep-processed categories such as cold-rolled stainless steel plates and galvanized steel plates is raised to 11%.

The key practical detail here is the accurate classification of HS codes: the difference in tax refund rates between different codes under the same large category can reach 2 to 4 percentage points.In 2025,a steel export enterprise in Zhejiang confused HS codes 72193100 (cold-rolled stainless steel plate) and 72193200 (hot-rolled stainless steel plate),under-declared tax refund of 1.27 million yuan,and later recovered the loss through pre-classification services.Enterprises should complete the pre-audit of HS codes 10 working days before customs declaration to avoid subsequent obstruction of tax refund.

Practical Operation of the Correlation Between Certificate of Origin and Tax Refund

In 2026,the binding requirements for export tax refund and certificate of origin are further tightened,and document requirements vary significantly among different export markets:

• RCEP member states: Form R certificates can be used to enjoy the regional cumulative rule of origin,while improving tax refund approval efficiency by more than 30%
• EU market: Both formal CO certificate of origin and CBAM carbon footprint test reports are required.The coverage of CBAM is expanded to semi-finished steel products in 2026,and failure to submit the report will directly lead to the failure of tax refund filing
• US market: A CO certificate of origin recognized by US Customs is required,while anti-dumping response materials shall be retained to avoid the impact of additional tariffs under Section 232 on tax refunds

In 2025,a Suzhou-based enterprise exported carbon steel profiles to the EU,and its tax refund was delayed for 3 months due to failure to submit the CBAM carbon footprint report in time,resulting in a capital occupation cost of about 80,000 yuan.Enterprises should contact third-party testing institutions in advance to complete carbon footprint accounting,and reserve at least 15 working days for document review.

2026 Steel Export Tax Refund Risk Early Warning Checklist

• Incorrect HS code classification: The customs tax refund random inspection rate is increased to 35% in 2026.Once classification inconsistency is verified,all tax refund funds will be recovered and late fees will be charged
• Counterfeit certificate of origin: Enterprises that forge Form R or CO certificates will be suspended from tax refund eligibility for 1 to 3 years,and will be included in the customs credit punishment list at the same time
• Weight measurement error disputes: The error between draft survey weight and weighbridge weight for bulk steel cargoes is usually between 0.5% and 1%.Some freight forwarders fail to agree on weight measurement standards in advance,which will lead to inconsistency between the tax refund amount and actual exported goods
• Hidden demurrage trap: If the responsibility division for demurrage incurred by steel cargoes detained at ports is not clearly defined,enterprises may not be able to claim compensation from freight forwarders,which directly increases export costs
• Overdue foreign exchange receipt: Failure to complete foreign exchange receipt verification within 180 days after goods export will make enterprises ineligible for the tax refund policy,and tax shall be levied as for domestic sales

Practical Case Review

In November 2025,a steel trading enterprise in Guangdong exported angle steel to the US,encountered an additional 24% tariff under the US Section 232,and its tax refund declaration was rejected due to incorrect HS code classification.After our team intervened,we completed the operation according to the following steps:

• Assist the enterprise to complete HS code pre-classification,adjust to the correct code 73042900,matching the 13% tax refund rate
• Collect anti-dumping response materials from the US importer to prove that the product is not within the scope of anti-dumping taxation
• Handle the endorsement of the US CO certificate of origin,and submit it to the customs tax refund audit department simultaneously

In the end,the enterprise successfully recovered 1.12 million yuan of tax refund,and was exempted from the 24% Section 232 tariff,saving a total cost of about 3.8 million yuan.

Exclusive Service Advantages of Shanghai Port

As a local foreign trade service institution in Shanghai,we provide cross-port tax refund declaration services for ports across the country,eliminating the need for enterprises to set up branches at the customs declaration location.Meanwhile,we link with the global agency network to provide localized document review services for major export markets such as Southeast Asia,Europe,America and the Middle East,and avoid tariff risks in destination countries in advance.

For bulk steel cargoes,we can coordinate with port weighing institutions in advance to agree on a unified weight measurement standard,avoiding subsequent deviations in tax refund amounts.We also establish a demurrage recovery mechanism to assist enterprises in recovering additional port fees from responsible parties.