Operation Guide for Export Agency Services for Non-Tax-Refundable Goods

Core Policy Interpretation

After the 2026 revision of the Export Tax Rebate Rate Adjustment Catalogue,the export tax rebate rate for some goods has been officially set to 0%.This change directly affects resource-based products such as steel,aluminum,and copper products,as well as some chemical products and primary processed goods.Ms.Zhang has been exporting hardware products in Shanghai for 15 years.Recently,she found that the tax rebate rate for the aluminum alloy profiles her company mainly exports has been directly adjusted from 13% to 0%,which means the cost structure will undergo a fundamental shift for every $1 million worth of goods exported.

The policy adjustment is not simply canceling tax rebates,but introduces a brand-new regulatory framework.The customs implements an enhanced review mode of "consistent documents and matching between documents" for non-tax-refundable goods,and the State Administration of Foreign Exchange (SAFE) has increased the frequency of foreign exchange receipt verification from quarterly to monthly.Enterprises need to understand three key changes: first,the tax rebate declaration process is eliminated,but the importance of customs declaration documents has actually increased; second,the cost accounting benchmark has shifted from tax-inclusive price to tax-exclusive price,and pricing strategies need to be redesigned; third,foreign exchange receipts and payments must strictly match customs declaration data,and any deviation may trigger verification.

Specific Scope of Tax Rebate Rate Adjustments

This adjustment involves 43 eight-digit tariff codes under Chapters 72,74,and 76 of the Customs Tariff Codes,mainly including steel,aluminum,and copper products in primary form and their simply processed goods.The common characteristics of these products are high energy consumption and relatively low added value.The policy aims to guide industrial upgrading and restrict exports of primary products.For exporting enterprises,the first priority is to identify whether their products are on the list.Zhongshen’s customs declaration team has established a tariff code database,and customers can quickly confirm the tax rebate rate status by providing product specifications and models.

Substantial Changes in Customs Regulatory Methods

Non-tax-refundable goods no longer need to prepare documents such as tax rebate coupons and VAT invoice certification,but the customs has significantly strengthened the verification of the authenticity of goods value.Recently,multiple cases questioned by customs due to under-declared value have occurred at the Shanghai Port.Under the new regulatory model,enterprises need to retain complete proof of cost composition,including raw material purchase contracts,processing fee payment vouchers,utility cost allocation records,etc.These documents will become key evidence to prove the authenticity of the declared price during customs audits.

Detailed Requirements for Foreign Exchange Verification Rules

SAFE has listed non-tax-refundable goods as "focused supervision" business,and the foreign exchange receipt time,amount,and payer must strictly match customs declaration information.Ms.Ke’s company was required by SAFE to provide an explanation last year because the receipt date exceeded the customs declaration date by 90 days due to the customer’s installment payments.The 2026 new rules shorten this time window to 60 days,and do not allow cumulative deviation exceeding 5% of the declared amount.This puts forward higher requirements for enterprises’ foreign exchange management capabilities.

Dual Impacts on Enterprises

Opportunities: Simplified Processes and Improved Capital Efficiency

After the tax rebate rate is set to 0%,enterprises no longer need to spend manpower organizing tax rebate documents or wait 2-3 months for tax rebate funds to arrive.Ms.Zhang calculated that her company exports about $500,000 worth of non-tax-refundable goods per month,and previously needed to advance about $65,000 in VAT,with a capital occupation cost of nearly $2,000 per month during the waiting period for tax rebates.After canceling the tax rebate,this part of the financial pressure has directly disappeared,and the cash flow situation has significantly improved.

• Document workload reduced by over 40%,no need to check the matching between tax rebate coupons and VAT invoices
• Capital turnover speed improved,the shortest cycle from shipment to full payment collection shortened to within 30 days
• More flexible pricing strategies,no need to consider the impact of tax rebate arrival time on customer payment terms

Challenges: Cost Accounting and Compliance Pressure

Non-tax-refundable means VAT has become a real export cost.The chemical trading company of Manager Jia exports a dye product with a tax rebate rate of 0%.Previously,the purchase cost was 100 yuan (including 13% VAT),with a tax rebate of 13 yuan,and the actual cost was 87 yuan.Now that tax rebates are unavailable,the cost directly becomes 100 yuan.If the original sales price is maintained,profits will be completely squeezed.What’s more complicated is that the customs requires the declared FOB price to include this portion of VAT,but foreign customers do not understand China’s tax system changes,leaving extremely limited bargaining room.

• Chaotic cost accounting benchmarks,the finance department needs to rebuild a tax-exclusive cost calculation model
• Rising document compliance risks,customs declaration price,foreign exchange receipt amount,and purchase invoice must form a complete evidence chain
• Reduced tolerance for foreign exchange receipts and payments,any data mismatch may trigger regulatory inquiries

Zhongshen’s Response Strategies

Precise Cost Calculation and Pricing Support

Zhongshen has developed a specialized cost calculation tool for customers of non-tax-refundable goods.By inputting parameters such as tax-inclusive purchase price,tax rebate rate,sea freight,and port charges,the system automatically calculates the break-even FOB price and recommended sales price.After using this tool,Mr.He’s metal products company found that previously marginal loss-making products could actually achieve a 3% net profit by adjusting packaging methods and using consolidated customs declaration.The key lies in making VAT costs transparent and communicating the price composition with foreign customers during the quotation stage.

In addition,Zhongshen provides "batch cost allocation" services.For factories that produce both tax-refundable and non-tax-refundable products,we assist in establishing a reasonable cost allocation mechanism to ensure that the cost accounting of non-tax-refundable products does not erode the profits of tax-refundable products.This requires professional financial planning capabilities,which ordinary enterprises cannot complete independently.

Full-Process Control of Document Compliance

Zhongshen’s customs declaration team implements a "pre-examination system",reviewing all documents in advance before the goods are ready but not yet shipped.A batch of aluminum alloy profiles of Ms.Zhang was found to have slight differences between the specifications on the purchase invoice and the customs declaration form during the pre-examination,and was corrected in time to avoid customs inspection.For non-tax-refundable goods,Zhongshen additionally provides a "cost composition proof package" service,organizing documents such as raw material purchase contracts,processing fee invoices,and energy consumption allocation forms to form a complete archival record for reference.

In the customs declaration process,Zhongshen leverages the data connection advantages of the Shanghai Port to pre-match customs declaration data with subsequent foreign exchange receipt information.The system can prompt potential mismatch risks before receiving foreign exchange,leaving customers time to make adjustments.This proactive management model transforms compliance risks from post-event remediation to pre-event prevention.

Foreign Exchange Receipt and Payment Risk Isolation

In response to the strict requirements of foreign exchange verification,Zhongshen has designed a "special funds for special purposes" management plan.We set up a separate foreign exchange receipt monitoring ledger for customers of non-tax-refundable goods,matching every foreign exchange income with the corresponding customs declaration form on the same day.After adopting this plan,even if the customer makes payments in three installments due to various reasons,Zhongshen can complete data consolidation on the day of receipt and generate a matching report that meets SAFE requirements.

For businesses that do have deviations in foreign exchange receipt time,Zhongshen assists in preparing complete commercial reasonableness explanations,including customer payment process documents,email communication records between both parties,industry practice certifications,etc.These documents can effectively prove the authenticity of the business when responding to SAFE verification and avoid being included in the abnormal list.

Practical Cases and Cost Comparison

Taking the non-tax-refundable aluminum alloy profiles exported by Mr.He’s company as an example,compare the differences between self-operation and entrusting Zhongshen as the agent:

Data shows that although agency services incur direct costs,the implicit benefits brought by reduced error rates and improved efficiency are more significant.Especially for small and medium-sized enterprises with annual export volumes ranging from $3 million to $10 million,the comprehensive cost of professional agency services is actually lower.

Action Recommendations for Export Enterprises

Facing the full implementation of the 2026 non-tax-refundable goods policy,the most urgent action for enterprises is to re-evaluate their product pricing models.It is recommended to immediately organize a tripartite meeting of finance,sales,and customs departments to calculate the real cost of each product based on the latest tax rebate rate catalogue.For products confirmed to be on the non-tax-refundable list,price communication with foreign customers should be completed before quoting for the next order.At the same time,establish an internal document review mechanism,or entrust a professional agency to conduct pre-examination,to avoid additional costs caused by customs declaration errors.Zhongshen provides free preliminary policy impact assessment services; enterprises can provide product tariff codes to quickly obtain customized response plans.