Latest Interpretation of 2026 Regulations on Consigned Export of Goods

Analysis of Core Changes to 2026 Regulations on Consigned Export of Goods

Last week,Supervisor Sheng from a new energy enterprise in Shanghai called Zhongshen,saying that for their photovoltaic components exported via consigned agency in the first quarter of 2026,they heard there are new tariff adjustments but are unsure how to apply for reduction.In fact,this is driven by the newly released 2026 regulations on consigned export of goods — the policy not only adjusts the tax refund process and expands tariff preferences for specific commodities,but also puts forward stricter requirements for compliance filing.

I.Three Key Points of 2026 Regulations on Consigned Export of Goods

Combined with Announcement No.12 of 2026 from the General Administration of Customs of China,core adjustments to the regulations on consigned export of goods focus on three aspects:

• Clear Tax Refund Declaration Subject and Time Limit: The new regulations require that tax refund declaration for consigned export must be handled by the consignee,and the Export Tax Refund Power of Attorney issued by the consignor must be provided; the declaration time limit has been compressed from the original 60 days to 30 days,and overdue declaration will affect tax refund progress.
• Expanded Tariff Reduction Scope for Specific Commodities: For 12 categories of commodities including mechanical and electrical products and new energy components,tariff reduction can be enjoyed for consigned export (some commodities reduced from the original 3%-5% to 0),but agency agreements and commodity traceability certificates (such as certificate of origin,production batch records) must be provided at the same time.
• Mandatory Requirement for Electronic Filing of Agency Agreements: All agency agreements for consigned export business must complete electronic filing on the China International Trade Single Window,and unfiled agreements cannot be used as valid certificates for foreign currency receipt,payment and settlement.

II.Opportunities and Challenges of the New Regulations for Export Enterprises

After the implementation of the new regulations,Shanghai foreign trade enterprises have both gained opportunities for cost reduction and efficiency improvement,and face challenges of increased compliance difficulty:

In terms of opportunities,the clear definition of tax refund declaration subject reduces operation steps for the consignor — for example,in 2025,a clothing enterprise experienced tax refund delay due to repeated declaration by both the consignor and consignee; after the 2026 new regulations,the consignee handles the declaration uniformly,which can avoid such problems.Meanwhile,according to the calculation of a Shanghai photovoltaic enterprise,tariff reduction for new energy components and other commodities can save about 120,000 RMB in tariff cost in the first quarter.

In terms of challenges,first,compliance requirements are stricter — electronic filing requires familiarity with Single Window operation,and financial staff of some small,medium and micro enterprises are not familiar with the new process; second,the provision of commodity traceability certificates,for example,some mechanical and electrical products need to trace production records of upstream suppliers,which increases the complexity of material preparation.

III.How Does Zhongshen Help Enterprises Implement New Regulation Requirements

In response to enterprises’ confusion,Ms.Tong’s team at Zhongshen has summarized a set of implementation plans,with the core of "advance policy pre-review + full-process managed service",the specific service comparison is as follows:

For example,Manager Zhang from a mechanical and electrical enterprise in Shanghai entrusted Zhongshen to export a batch of motors in February 2026.Ms.Tong’s team first verified whether the motor’s commodity code falls within the scope of tariff reduction,assisted in preparing the certificate of origin and production batch records after confirming eligibility; meanwhile guided the enterprise to complete agency agreement filing on the Single Window,avoiding foreign exchange settlement delay caused by missing filing.Finally,this batch of motors not only enjoyed zero tariff,but also the tax refund arrived within 20 days,saving about 80,000 RMB in cost compared with 2025.

IV.One Practical Suggestion for Enterprises to Cope with the New Regulations

Before signing a consigned export agency agreement,be sure to clarify the "scope of tax refund authorization" — many enterprises only state "entrust consigned export" in the power of attorney,and do not clearly specify "authorize the consignee to handle export tax refund on behalf",which leads to failure to complete tax refund declaration under the new regulations.It is recommended that enterprises add the following clause to the agreement: "The consignor authorizes the consignee as the sole tax refund declaration subject,responsible for submitting tax refund materials to the tax authority and receiving tax refunds",and attach the consignor’s official seal and legal person’s signature.

The adjustment of 2026 regulations on consigned export of goods is essentially a refinement of foreign trade supervision — it reduces costs for compliant enterprises and eliminates non-compliant operations.Zhongshen has been deeply engaged in the industry for 20 years,is familiar with the actual needs of Shanghai foreign trade enterprises,and can help enterprises quickly adapt to the new regulations and seize policy dividends.