2026 Export Goods Tax Refund Declaration Documents: Core Requirements and Practical Operation Guide

I.Core Policy Adjustments to Export Goods Tax Refund Declaration Documents in 2026

Starting in 2026,China’s export tax refund policy will simultaneously advance optimization and tightening of the document declaration process,with core adjustments focusing on three dimensions: electronic data verification,specific product association requirements,and retention time limits,directly affecting the efficiency and pass rate of enterprises’ tax refund declarations.

1.Mandatory Upgrade of "Three-Party Consistency Verification" for Electronic Documents

In 2026,the tax authorities,together with the customs and foreign exchange administrations,launched a "cross-departmental data sharing and verification system",requiring that the three core documents for export tax refund declaration - export invoices,customs declarations,and foreign exchange receipt vouchers - must achievefull matching of commodity codes,quantities,and amounts.Previously,enterprises could make up for differences within 1% through "manual explanations",but in 2026,pre-verification of data must be completed at the electronic port in advance,otherwise the system will directly intercept the declaration.

Take the experience of Mr.Zhu from a Shanghai-based electronic product export enterprise as an example: In 2025,he successfully passed the audit with a handwritten explanation due to the difference between "1000 pieces" on the customs declaration and "1001 pieces" on the invoice; but when declaring in January 2026,the system directly prompted "data inconsistency",and the documents needed to be adjusted before submission.

2.RCEP Commodity Tax Refund Requires Synchronized Association with Certificate of Origin

For export commodities enjoying RCEP tariff preferences in 2026,the policy adds a requirement that "electronic copies of RCEP certificates of origin must be uploaded synchronously for tax refund declaration",and the HS codes,commodity names,and manufacturer information on the certificates must be fully consistent with the customs declarations and tax refund declaration forms.If an enterprise fails to apply for the certificate of origin in advance,or if the information on the certificate conflicts with other documents,the tax refund declaration will directly fail to pass.

According to statistics from the Zhongshen International Trade document team,among the enterprises consulting this policy in the first quarter of 2026,60% are small and medium-sized enterprises exporting to RCEP member countries for the first time,and most of them have the situation of "complete documents but unable to declare" due to unfamiliarity with the procedures for handling certificates of origin.

3.Document Retention Period Extended to "5 Years After Declaration"

The 2026 policy clearly stipulates that the retention period for export tax refund declaration documents (including paper and electronic versions) has been extended from the original "3 years" to"5 years after declaration",and "document generation process records" must also be retained - such as electronic invoice issuance logs,customs declaration modification records,and bank flow details of foreign exchange receipts.The tax authorities will verify the integrity of the retained documents through "random spot checks + targeted verification",and enterprises that fail to retain documents as required will face the penalty of "suspension of tax refund qualification".

II.Impact of 2026 Document Policy Adjustments on Export Enterprises

III.Core Services of Zhongshen to Help Enterprises Implement Document Declarations

In response to the new requirements of the 2026 document policy,Zhongshen,relying on more than 20 years of foreign trade agency experience,provides enterprises with customized services of "pre-verification + full-process tracking" to help enterprises avoid compliance risks and improve tax refund efficiency:

• Electronic Document Pre-verification Service: After enterprises submit documents,the Zhongshen document team first conducts pre-verification with customs and foreign exchange data through the internal system,and checks for differences in commodity codes,quantities,amounts,etc.in advance,ensuring 100% compliance with consistency requirements before declaration.In the first quarter of 2026,it has helped 32 enterprises avoid declaration rejection;
• RCEP Certificate of Origin Agency Service: For commodities exported to RCEP member countries,Zhongshen can assist enterprises in applying for certificates of origin in advance,and synchronously complete information matching with customs declarations and tax refund declaration forms.The average processing time is shortened from 7 working days for enterprises to apply on their own to 3 working days;
• Document Retention Management Service: Provide enterprises with an electronic document storage system that automatically generates document generation process records,meets the 5-year retention requirement,and supports remote verification by the tax authorities,helping enterprises reduce internal management costs.

IV.Action Suggestions for Enterprises to Respond to the 2026 Document Policy

In response to the new requirements of the 2026 export tax refund document declaration,it is recommended that enterprises complete the electronic data verification through Zhongshen’s "Document Pre-verification Tool" before each monthly declaration - focus on checking whether the commodity codes of export invoices,customs declarations,and foreign exchange receipt vouchers are consistent.If there are differences,contact the logistics or supplier to adjust in time to avoid declaration rejection due to "data inconsistency".