Cross-Border E-Commerce Customs Codes: 9610/9710/9810/1210 Explained for China Sellers in 2026

Key Takeaway: China's four cross-border e-commerce customs codes — 9610, 9710, 9810, and 1210 — determine your tax treatment, declaration workflow, and refund eligibility. Picking the right code in 2026 can save months of tax-refund delays and cut compliance costs by over 40%.

Quick Facts

Four Codes, Four Fulfillment Realities

Every shipment leaving or entering China under a cross-border e-commerce model carries a four-digit supervision code assigned by the General Administration of Customs. For sellers, the code you declare is not a clerical formality — it dictates your tax liability, your declaration workflow, and whether you can claim a VAT refund at all.

The four core codes are 9610 (B2C direct-mail retail export), 9710 (B2B direct export), 9810 (B2B export via overseas warehouse), and 1210 (bonded warehouse import/export). Code 9610 was established in January 2014 (source), while 9710 and 9810 were added together in July 2020 under General Administration of Customs Announcement No. 75 of 2020, initially piloting across 10 customs districts before expanding to 22 (source). Code 1210 governs bonded warehouse operations and is the primary channel for high-speed consumer goods that require pre-positioning in China's 165 special customs supervision areas.

Understanding the distinction matters because China's cross-border e-commerce sector handled ¥2.84 trillion in import and export trade in 2025, up 4.8% year-over-year (source), and the tax-refund implications of choosing the wrong code can cost a seller six figures in RMB.

9610: The Direct-to-Consumer Workhorse

Code 9610 is the backbone of China's B2C cross-border retail export. It was the first dedicated supervision code for cross-border e-commerce, introduced in 2014, and operates on a "list-based release, consolidated declaration" model. Each individual parcel clears customs through a declaration list rather than a full customs declaration form, which keeps per-parcel clearance costs significantly lower than the ¥300–500 required under traditional 0110 general trade.

The core compliance mechanism under 9610 is the **three-document match: the order, the payment record, and the logistics data must all align when transmitted through China's Single Window system before customs releases the shipment. If any of these three data streams fail to match — for example, a logistics weight that doesn't correspond to the order — the parcel gets held at customs. Industry data suggests that roughly 3% of 9610 direct-mail shipments face detention by US customs alone, making data accuracy a financial risk, not just a compliance checkbox (source).

One of 9610's most powerful advantages for small and medium sellers is the no-invoice tax exemption policy available within the 178 comprehensive cross-border e-commerce pilot zones. Under this policy (originally established by Caishui [2018] No. 103), sellers who cannot obtain valid purchase invoices can still enjoy VAT and consumption tax exemption, plus a corporate income tax assessment rate of just 4%. For micro-enterprises with annual sales under ¥25 million, the effective income tax burden drops to approximately 1‰ — effectively ¥10,000 in tax on ¥10 million in revenue (source).

According to the General Administration of Customs, 9610 consolidated declaration must be completed by the 15th of the following month, grouping all cleared lists under the "eight same" rule — same consignor/consignee, same transport mode, same production/sales entity, same destination country, same exit customs, same ultimate destination, same 10-digit HS code, and same currency (source).

A major 2026 update under the State Taxation Administration's Announcement No. 5 extended the export tax-refund declaration window to 36 months from the date of export (source). Before this reform, sellers who missed the deadline faced reclassification as domestic sales and full taxation. The 36-month window gives sellers significantly more time to reconcile their documentation, but the clock is now ticking on every single export transaction.

9710 and 9810: The B2B Export Duo

While 9610 handles fragmented B2C orders, codes 9710 and 9810 serve the B2B export channel — and the distinction between them hinges on one factor: whether the goods go directly to a foreign enterprise or to an overseas warehouse first.

9710 (B2B Direct Export) applies when a Chinese seller transacts online with an overseas enterprise and ships directly to that enterprise — no overseas warehouse staging involved. The declaration process runs through the Single Window system, and for shipments under ¥5,000 per ticket that don't involve permits, inspections, or taxes, sellers can use a simplified list declaration. For larger orders, the full H2018 customs system applies. The VAT refund treatment mirrors that of 0110 general trade, with refund rates reaching up to 13% for most manufactured goods. However, sellers must maintain full alignment between their declared customs value and the actual foreign exchange received — a mismatch is one of the most common reasons for refund delays under this code.

9810 (B2B Export via Overseas Warehouse) is designed for sellers who pre-position inventory in an overseas warehouse — whether Amazon FBA, a third-party facility, or a self-built warehouse. The key advantage is the pre-refund at departure mechanism: once goods clear customs and leave China, the seller can immediately apply for a VAT refund under business code HWC-YT ("overseas warehouse pre-refund"). This dramatically accelerates cash flow compared to the traditional model where refunds only arrived after the goods were sold abroad, typically taking 1–3 months. The settlement period runs from the month following the pre-refund through April of the following year (source).

According to the Ministry of Finance's 2026 Announcement No. 16, goods exported under 9810 (alongside 9610, 9710, and 1210) that are returned within 6 months due to slow sales or customer returns are exempt from import duties, VAT, and consumption tax — a policy now extended through December 31, 2027 (source). This return exemption effectively de-risks the overseas warehouse model: if your inventory doesn't sell, you can bring it back tax-free.

The 9810 model delivers a 70% improvement in delivery speed for end consumers, with US local delivery averaging 1–2 days compared to the 7–15 day timelines typical of direct-mail 9610 (source). As of mid-2026, China has over 2,500 overseas warehouses supporting this model.

According to professional tax advisory firms, not all product categories qualify for full refunds. Starting April 1, 2026, solar panel products face a 0% refund rate (completely eliminated), while battery products are in a transitional 6% rate that drops to 0% from January 2027 (source). Sellers in these categories should factor the lost refund into their pricing strategy regardless of the code they choose.

1210 and the Bonded Route

Code 1210 governs bonded warehouse operations and serves both import and export flows. For export-oriented sellers, 1210 allows goods to enter a comprehensive bonded zone and immediately trigger an export tax refund — effectively getting the refund before the goods even leave China. The goods are then held in the bonded warehouse and dispatched to overseas consumers as orders come in.

For the import side, which remains 1210's primary use case, overseas sellers pre-position bulk inventory in Chinese bonded warehouses. When a consumer places an order, the goods clear customs from the bonded zone and are delivered domestically. The cross-border e-commerce comprehensive tax rate of 9.1% is significantly lower than standard general trade rates, and individual orders are subject to a per-transaction limit of ¥5,000 and an annual consumer limit of ¥26,000 (source).

The 1210 model is currently available across 37 designated cities. Its main operational challenge is inventory planning — overstocking in a bonded warehouse ties up capital, while understocking defeats the speed advantage that makes the model attractive in the first place. Sellers must also complete the full sales cycle before the tax-refund loop closes.

Choosing Your Code: A Practical Decision Framework

The following comparison matrix summarizes the six key dimensions that matter most for sellers choosing between the four codes:

For sellers operating without valid purchase invoices, the 9610 no-invoice exemption remains the most cost-effective path, provided you operate within one of the 178 pilot zones. For sellers with overseas warehouse operations, 9810's pre-refund-at-departure mechanism delivers a material cash-flow advantage over the traditional wait-until-sale model. And for B2B exporters receiving large orders through e-commerce platforms, 9710 offers the same refund rates as general trade but with a streamlined declaration process and priority customs inspection.

A critical mistake to avoid in 2026: failing to file your export tax refund within the 36-month window. Under the State Taxation Administration's new regulations, any export transaction left unclaimed after 36 months is reclassified as a domestic sale and taxed accordingly. With 11 distinct scenarios now triggering on-site tax audits — including first-time filers, high-risk product categories, and abnormal pricing patterns — the cost of non-compliance has risen sharply (source). In December 2025 alone, Shenzhen customs intercepted 127 cases of "maidan" (document-purchasing) exports involving goods worth over ¥230 million, signaling that enforcement is no longer theoretical.

FAQ

Q1: What is the difference between customs codes 9610, 9710, 9810, and 1210?

9610 covers B2C retail direct-mail exports with list-based clearance. 9710 is for B2B direct export where goods ship straight to a foreign enterprise. 9810 handles B2B exports to overseas warehouses with pre-refund at departure. 1210 governs bonded warehouse operations for both import and export. Each code triggers different declaration workflows and tax treatments.

Q2: Which customs code should I use if I sell on Amazon FBA?

If you use Amazon FBA or any overseas warehouse, code 9810 is typically the best choice. It allows you to claim a VAT refund as soon as goods clear customs and leave China — under the HWC-YT pre-refund mechanism — rather than waiting until items are sold abroad. For a detailed walkthrough of the declaration process, CNBusinessHub has published a step-by-step guide in our cross-border compliance library.

Q3: Can I claim a VAT refund under 9610 if I don't have purchase invoices?

No — the 9610 VAT refund requires valid purchase invoices. However, if you operate within one of the 178 comprehensive cross-border e-commerce pilot zones, you can use the no-invoice tax exemption policy instead, which exempts you from VAT and consumption tax and applies a 4% corporate income tax assessment rate. For small enterprises under ¥25 million in annual revenue, the effective tax burden drops to roughly 1‰.

Q4: What is the "three-document match" requirement?

Under 9610, customs requires that the order data (from the platform), the payment data (from the payment processor), and the logistics data (from the shipping provider) all match when transmitted through China's Single Window system. If any discrepancy exists — mismatched weights, prices, or buyer information — the shipment will not clear customs. This is the single most important compliance checkpoint for 9610 sellers.

Q5: How long does it take to receive an export tax refund?

For 9610 and 9710, the typical refund cycle is 1–3 months after the consolidated customs declaration is filed. Under 9810, the pre-refund mechanism allows you to receive the refund at departure, with final settlement running from the month following pre-refund through April of the next year. Processing times vary by local tax bureau.

Q6: What happens if I miss the 36-month export refund deadline?

Under the State Taxation Administration's 2026 Announcement No. 5, any export transaction not claimed within 36 months of the export date is reclassified as a domestic sale and subject to full domestic taxation — including VAT at the applicable rate. There is no grace period beyond 36 months.

Q7: What is the return exemption policy for cross-border e-commerce?

Under the Ministry of Finance's 2026 Announcement No. 16, goods exported under codes 1210, 9610, 9710, or 9810 that are returned within 6 months of export due to slow sales or customer returns are exempt from import duties, import VAT, and consumption tax. This policy is valid from January 1, 2026 through December 31, 2027. Note that food products are excluded.

Q8: Can I return 9610 goods through any customs office?

Yes. Since April 1, 2026, the General Administration of Customs has promoted 9610 cross-zone returns nationwide. Sellers can process returns through any customs office in China, not just the original exit point. As of February 2026, the pilot program had already handled 381,300 return tickets worth ¥9.4 million. Read our full guide on CNBusinessHub for the latest return procedures.

Q9: What product categories lost their VAT refund in 2026?

Starting April 1, 2026, solar panel products face a 0% refund rate (fully eliminated). Battery products entered a transitional 6% refund rate that will drop to 0% from January 2027. Most other manufactured goods retain the standard 13% rate.

Q10: What is the maximum value per shipment under simplified 9610 declaration?

For 9610, shipments valued at ¥5,000 or less per ticket that don't require permits, inspections, or taxes can use the simplified "list-based release, consolidated statistics" method without generating a full customs declaration form. The same ¥5,000 threshold applies to simplified declarations under 9710.

Q11: How many overseas warehouses support the 9810 model?

As of 2026, China has over 2,500 overseas warehouses supporting the 9810 export model. These include Amazon FBA facilities, third-party warehouse operators, and seller-owned warehouses. The 9810 model enables 1–2 day local delivery in the US market — a 70% speed improvement over direct-mail alternatives.

Q12: What are the main risks of using code 9810?

The primary risks include complex overseas warehouse filing requirements, the need to reconcile pre-refund amounts against actual sales (which creates an extensive evidence chain), and potential discrepancies between declared export values and realized sales prices. Additionally, the settlement period runs through April of the following year, requiring careful tax planning. CNBusinessHub's compliance team maintains an updated risk checklist for overseas warehouse operators — available in our resource library.

Q13: What is the 1210 per-consumer spending limit?

Under code 1210 for bonded import, individual consumers face a per-transaction limit of ¥5,000 and an annual cumulative limit of ¥26,000. The comprehensive tax rate of 9.1% applies instead of general trade rates. These limits apply to the import side of 1210; export-side operations follow separate rules.

Q14: When was the 9610 cross-zone return policy rolled out nationally?

The General Administration of Customs announced the national rollout of 9610 cross-zone returns in Announcement No. 24 of 2026 (issued March 12, 2026), with implementation beginning April 1, 2026. Prior to this, the program operated as a pilot across 20 designated customs districts starting December 2024.

Q15: Can individual business owners (registered as sole proprietors) use the 9710 or 9810 codes?

Yes, provided the entity is properly registered for cross-border e-commerce activities and has completed the required customs filings. The key difference is that individual business owners typically cannot claim VAT refunds under 9710 or 9810 because they usually lack general taxpayer status and valid purchase invoices. In such cases, 9610's no-invoice exemption or the 1039 market procurement trade model may be more appropriate.

Conclusion

Choosing the right customs supervision code in 2026 is no longer a back-office administrative decision — it is a strategic choice that shapes your cash flow, your delivery speed, and your compliance risk profile. The 9610 code remains the most accessible option for small and medium sellers, especially with the no-invoice exemption available across 178 pilot zones. The 9810 model delivers the fastest refund cycle through its pre-refund-at-departure mechanism, making it the clear winner for sellers with established overseas warehouse operations. The 9710 code bridges the gap for B2B exporters who need the refund rates of general trade but want the streamlined declaration process of e-commerce. And 1210 continues to serve the high-speed, pre-positioned inventory model for both import and export flows.

With the 2026 regulatory updates — the 36-month refund window, the extended return exemption through 2027, and the nationwide rollout of 9610 cross-zone returns — the compliance landscape is more structured than ever. Sellers who align their code choice with their actual business model and maintain clean documentation will navigate the system efficiently. Those who treat customs codes as an afterthought risk refund delays, tax penalties, and in the worst cases, full reclassification of exports as domestic sales.

Sources

1. General Administration of Customs of China — https://www.customs.gov.cn
2. Ministry of Finance Announcement No. 16 of 2026 (return exemption extension) — https://www.yidaiyilu.gov.cn/p/0CHN7K9N.html
3. State Taxation Administration Announcement No. 5 of 2026 (export tax-refund reform) — https://fgk.chinatax.gov.cn/zcfgk/c100012/c5247423/content.html
4. GAC Announcement No. 75 of 2020 (9710/9810 pilot) — http://swj.wuhai.gov.cn/swj/843439/843564/843569/843637/1430328/index.html
5. Caishui [2018] No. 103 (no-invoice exemption) — https://www.shui5.cn/article/dd/78889.html
6. Shanghai Cross-Border E-Commerce Association (9610 declaration rules) — https://www.scea.co/trends/show/id/3853.html
7. ingstart (six customs clearance modes analysis) — https://www.ingstart.com/blog/35214.html
8. Xiamen Tax Bureau (9810 pre-refund) — http://en.swj.xm.gov.cn/2025-02/17/c_1070611.htm
9. Kinyu (China Export Supervision Codes 2026 Guide) — https://www.kinyu.co.uk/china-export-supervision-codes-a-complete-2026-guide
10. professional tax advisory firms (Export VAT Refund 2026) — https://msadvisory.com/export-tax-refunds-in-china
11. Chinackts (export tax-refund risk audit) — https://www.chinackts.com/news/925.html

---

This article is provided for informational purposes only and does not constitute legal, tax, or regulatory advice.

The information presented here should not be relied upon as a substitute for professional advice tailored to your specific circumstances.

All data referenced in this article is sourced from publicly available channels including government announcements, official customs publications, and industry reports. CNBusinessHub makes no warranty regarding the accuracy or completeness of third-party data.

© 2026 CNBusinessHub. All rights reserved.

---

1. Title: Cross-Border E-Commerce Customs Codes 9610 9710 9810 1210 Explained for China Sellers 2026
2. Description: Complete guide to China customs code 9610, 9710, 9810, and 1210 for cross-border e-commerce sellers in 2026. Covers declaration workflows, VAT refund eligibility, tax exemption policies, and a decision matrix.
3. Keywords: customs code 9610, customs code 9710, customs code 9810, customs code 1210, china cross border ecommerce customs, cross border ecommerce customs codes 2026, 9610 customs clearance, 9810 overseas warehouse, china export tax refund, china customs supervision codes, cross border ecommerce china seller guide