Is EXW Export Eligible for Tax Refund in 2026? Policy Interpretation and Practical Guide

Breakdown of Core Points of 2026 EXW Export Tax Refund Policy

Manager Wang of a garment foreign trade enterprise in Shanghai recently encountered a problem — he accepted an export order under EXW terms at the end of last year,and was required by the tax authority to supplement a "transportation responsibility certificate" when applying for tax refund,which confused him: Is EXW export really eligible for tax refund?What new changes are there in the 2026 policy?With these questions,we combine the practical experience of General Manager Fan’s team at Zhongshen to break down the core policy points of 2026 EXW export tax refund.

1.Core Premise of Tax Refund Declaration: Consistency Between Customs Declaration and Actual Transaction

The newly revised 2026 Administrative Measures for Value-Added Tax and Consumption Tax on Exported Goods and Labor Services clarifies that whether export goods under the EXW (Ex Works) model are eligible for tax refund depends on whether the trade term statement on the customs declaration is consistent with the actual transaction contract.General Manager Fan explained that many enterprises hold a misunderstanding: they think that since the seller is not responsible for transportation under EXW,no transportation documents are required.But in fact,the tax authority needs to confirm that the goods have indeed been exported,so "EXW" must be accurately marked on the customs declaration,and the contract must clearly stipulate that "the seller completes delivery obligations at the factory,and the buyer is responsible for subsequent transportation,customs declaration and customs clearance".

For example,an electronics enterprise in Shanghai exported a batch of components in January 2026.Due to incorrectly filling "FOB" on the customs declaration,the tax authority determined "trade term inconsistent with contract",and the tax refund application was rejected.Only after General Manager Fan’s team assisted in modifying the statement on the customs declaration did the enterprise successfully complete the tax refund declaration.

2.Impact of Transportation Responsibility Division: Key Documents Sellers Need to Retain Under EXW

The 2026 policy adds a requirement for "transportation responsibility division certificate".Among 3 recent EXW export tax refund cases handled by General Manager Fan’s team,2 were required to supplement documents due to lack of "buyer’s transportation entrustment agreement".Specifically,the core documents that sellers need to retain under the EXW model include:

• Official trade contract signed with the buyer (clearly stipulating EXW terms and attribution of transportation responsibility)
• Goods acknowledgment of receipt upon factory delivery (signed and confirmed by the buyer or their designated agent)
• Transportation agreement of the buyer entrusting a third-party freight forwarder (or receipt certificate issued by the freight forwarder)
• Customs declaration for export goods (with "EXW" trade term accurately marked)

3.2026 Tax Refund Rate Adjustment: Tax Refund Rate of Some Products Increased to 17%

According to the 2026 Export Tax Refund Rate Adjustment Catalogue released by the Ministry of Finance at the end of 2025,the tax refund rate for some mechanical and electrical products exported under the EXW model (such as small household appliances,auto parts) increased from 15% to 17%,and the tax refund rate for some textile and apparel products increased from 13% to 14%.General Manager Fan reminds that enterprises should accurately select categories such as "mechanical and electrical products" and "textile and apparel" in the tax refund system during declaration,to avoid incorrect application of tax refund rate caused by classification errors.

For clothing orders exported via EXW by a textile enterprise in Shanghai from January to February 2026,the tax refund amount increased by about 8% compared with the same period last year due to accurate declaration of tax refund rate,which benefited from the pre-review of declaration materials by General Manager Fan’s team at Zhongshen.

Opportunities and Challenges of EXW Export Tax Refund Policy for Enterprises

The 2026 policy adjustment is both an opportunity of policy dividends and a challenge of increased compliance requirements for foreign trade enterprises adopting the EXW model.Combining recent cases of Shanghai enterprises served,General Manager Fan’s team summarized the following two points:

1.Opportunity: Tax Refund Declaration Becomes More Operable After Policy Clarification

• Expanded coverage of tax refund rate increase: The increase of EXW export tax refund rate for mechanical and electrical,textile and other industries directly increases enterprises’ cash flow;
• Simplified electronic declaration process: The tax authority launched a "Special Channel for EXW Export Tax Refund" in 2026.After enterprises upload electronic documents,the review period is shortened from the original 15 working days to within 10 working days;
• Clearer policy interpretation: The official website of the State Taxation Administration has added a "Frequently Asked Questions" section for EXW export tax refund,so enterprises can directly query operation key points.

2.Challenge: Complex Responsibility Division Easily Leads to Declaration Delay

General Manager Fan mentioned that 3 Shanghai foreign trade enterprises recently encountered problems in EXW export tax refund declaration,which are mainly concentrated in the following aspects:

• Deviation in trade term statement: An electronics enterprise incorrectly filled "EXW Shanghai" on the customs declaration,while the contract agreed "ex works delivery",leading the tax authority to determine "inconsistent delivery location";
• Missing key documents: A home furnishing enterprise lacked the "buyer’s transportation entrustment agreement",so it took 10 days to supplement documents,and the tax refund was delayed for 2 weeks;
• Delayed policy update: Some small and micro enterprises still prepare materials according to the old 2025 rules and do not retain the goods acknowledgment of receipt,leading to declaration failure.

How Zhongshen Helps Enterprises Implement EXW Export Tax Refund

In response to the policy requirements of EXW export tax refund,the professional team led by General Manager Fan at Zhongshen (with over 20 years of deep experience in the industry) provides "whole-process pre-review + dynamic policy update" services.The specific service content and enterprise benefits are as follows:

When Manager Li of a foreign trade enterprise in Shanghai handled EXW export tax refund through Zhongshen at the end of last year,General Manager Fan’s team reviewed the "ex works delivery" statement in his contract in advance,found that the original contract did not clearly specify "the buyer is responsible for customs declaration",and after timely modification,the tax refund arrived in only 8 working days,7 days earlier than expected.

Practical Suggestions for Enterprises to Deal with EXW Export Tax Refund

In response to the 2026 policy requirements,General Manager Fan gave a core practical suggestion: Before signing an EXW trade contract,enterprises can contact General Manager Fan’s team at Zhongshen in advance to review trade term statements and transportation responsibility clauses in the contract,and confirm customs declaration filling specifications,to avoid tax refund delay caused by misunderstanding of terms.

In addition,enterprises need to note: when delivering goods at the factory,the buyer or their designated agent must sign and confirm the goods acknowledgment of receipt; properly keep the transportation agreement of the buyer entrusting the freight forwarder,to prove the attribution of transportation responsibility during tax refund declaration.