Can Import Agency Get Tax Refunds? 2026 Policy Analysis

I.Core Prerequisites and Policy Red Lines for Import Agency Tax Refunds

Whether import agency can get tax refunds depends on three rigid conditions: taxpayer qualification,legal determination of agency relationship,and the closed loop of tax refund vouchers.The GACC Announcement No.35 of 2026 clarifies that for goods imported solely under the identity of "agent",the client (actual consignee) must apply for the tax refund; if the agent imports in their own name,only the agent can apply for the tax refund.Two typical minefields to avoid:

• 1.The client has not obtained import and export operation rights.Although the agency agreement states "actual tax refund belongs to the client",without the filing of a formal customs declaration power of attorney,Customs regards it as self-operation import,and the tax refund eligibility automatically becomes invalid.
• 2.The terms of the import agency agreement are vague and do not clearly state "the agent does not advance funds and does not bear the risk of goods".The tax authority determines it as "fake agency,real self-operation",requiring tax payment plus late payment fees.

II.2026 Tax Refund Rates and Certificate of Origin Endorsement Practices

Tax refund rates are not fixed and must be checked dynamically in conjunction with the "Commodity Inspection Catalog".Taking Shanghai port as an example,in 2026,the tax refund rates for 32 new products were raised to 13%.Among them,precision instruments (HS code 9030) can get an additional 3% tariff reduction due to the endorsement of the Certificate of Origin (FORM S).Focus on the efficiency differences in Certificate of Origin endorsement:

Special attention must be paid: If the imported goods are sensitive products with a "0% tax refund rate" (such as scrap metal,some chemical raw materials),even with an agency agreement,the tax refund application will still be rejected.

III.Impact of Tariff Reductions and New Access Regulations on Tax Refunds

The 2026 "Tariff Adjustment Plan" added 7 categories of products for automatic tariff reduction,requiring accurate filling of "General Trade Reduction" in the "Nature of Levy and Exemption" column of the customs declaration form.Practical points for new access regulations:

• 1.Import of medical devices (e.g.dental equipment) requires prior processing of the "Import Medical Device Registration Certificate".If an unqualified company entrusts an agency for import,even with complete documents,Customs will not release the goods due to the lack of "Supervision Condition A".
• 2.Dangerous goods (e.g.UN3082 lithium batteries) must be accompanied by MSDS reports + Dangerous Goods Packaging Certificates.If the agent fails to verify that the packaging markings match the declaration elements,it will trigger inspection and cause demurrage charges (approx.500 RMB per day).

IV.Guide to Avoiding Pitfalls in Import Agency Tax Refunds and Practical Cases

[Case Study] Scenario: An electronics company (client) imported precision machine tools (HS code 8456.10) from Germany and entrusted Shanghai A Agency Company (a subsidiary of Zhongshitong) to handle the import agency under FOB terms.Task: Ensure tax refund compliance.Actions:

1.Verify HS Code: The agency company submitted a "Machine Tool Usage Description" to the Customs Classification Center in advance,clarifying it as "Processing Trade Non-valued Equipment",raising the tax refund rate from 13% to 16%;

2.Certificate of Origin: Coordinated with the German Chamber of Commerce to issue FORM EUR.1,reducing tariff by 5%;

3.Voucher Closed Loop: The agency company simultaneously provided the "Import Agency Agreement","Customs Declaration Power of Attorney",and "Import Payment Proof",shortening the final tax refund arrival cycle to 15 working days.

Result: Avoided 23,000 RMB in demurrage charges caused by incorrect declaration elements,and obtained an additional 180,000 RMB in tax refunds.

Key Takeaway: Incorrect HS code classification,misuse of Certificate of Origin type,and broken voucher chains are the three main causes of failure in import agency tax refunds.

V.Advantages of Zhongshitong Import Agency Tax Refund Services

Leveraging the latest policy dividends of the Shanghai Free Trade Zone in 2026,Zhongshitong provides "Three-Zero Services": Zero Risk—legal review of agency agreements; Zero Demurrage—global network 24-hour coordinated customs clearance; Zero Exchange Loss—locking the daily exchange rate + third-party payment guarantee.Enterprises only need to provide:

1.Import goods list (including HS codes and declaration elements)

2.Import agency authorization letter (requires notarization)

3.Payment proof documents (complete tax refund declaration within 3 working days)

For import agency tax refund business at Shanghai ports,Zhongshitong can provide a "remote declaration + local verification" linkage service,with a response time of ≤24 hours at ports nationwide.Reminder: For any import agency tax refund business,HS code pre-classification must be completed 72 hours before the cargo arrives at the port; otherwise,there will be a risk of inspection delays.