2026 Export Tax Refund Policy Interpretation: Which Goods Are Eligible for Refund?

Core Breakdown of 2026 Export Tax Refund Policy: Not All Exports Qualify for Refunds

Since 2026,the number of inquiries about export tax refunds from Shanghai’s foreign trade enterprises has increased by 23% compared to the same period last year,with over 60% of enterprises confused about "whether all exported goods can enjoy tax refunds".According to the latest policies,export tax refunds do not have "full category coverage",and judgments need to be made from three dimensions: commodity type,trade mode,and compliance requirements.

1.Three Key Points of the 2026 Export Tax Refund Policy

• Dynamic Adjustment of Refund Rates: To meet the needs of optimizing foreign trade structure,the refund rates for green export categories such as mechanical and electrical products and new energy equipment remain at 13%.The refund rate for some high-end equipment (such as core components of industrial robots) has been increased from 11% to 13%; however,export tax refunds are cancelled for high-energy-consuming and high-pollution commodities (such as some ceramic building materials and low-end chemical raw materials),with the refund rate adjusted to 0%.
• Restrictions on Specific Trade Modes: For cross-border e-commerce direct mail (Model 9610) and market procurement trade (Model 1039),small-value commodities with a single invoice amount below 5,000 yuan are temporarily excluded from the tax refund scope; exports of offcuts under processing trade shall pay taxes as domestic sales and do not enjoy tax refunds.
• Upgraded Compliance Audits: Tax authorities require the provision of full-link transaction documents,including genuine purchase contracts,logistics bills of lading,and foreign exchange receipts,which must be accurately matched with commodity codes (HS codes).False transactions or incorrect codes will directly lead to the rejection of tax refund applications,and the audit rejection rate has increased by 12% compared to 2025.

2.Opportunities and Challenges of the Policy for Shanghai’s Foreign Trade Enterprises

(1) Opportunities: Tax Refund Benefits Tilt Toward High-Quality Categories

After the 2026 refund rate adjustment,the head of a Shanghai electronics enterprise,Director Dong,reported that the refund rate for the new energy charging piles exported by his company has been increased from 11% to 13%,allowing an additional 20,000 yuan in tax refunds for every 1 million yuan in export value,with the annual total tax refund increasing by over 300,000 yuan.Meanwhile,the tax authorities have implemented "digital tax refund audits",shortening the normal tax refund cycle in Shanghai from 15 working days to 10 working days,improving enterprises’ capital turnover efficiency by 30%.

(2) Challenges: Raised Compliance Thresholds,Enterprises Prone to "Pitfalls"

Some small and medium-sized foreign trade enterprises often encounter three types of problems due to lack of professional knowledge: First,incorrect classification of commodity codes (such as mislabeling ordinary building materials as new energy materials),leading to rejection of tax refund applications; Second,falsely applying for tax refunds for cross-border e-commerce direct mail commodities,resulting in a fine equal to the amount of the tax refund by the tax authorities; Third,failing to retain full-link documents and unable to provide proof of transaction authenticity.Jia,manager of a Shanghai clothing trading company,once had his tax refund application delayed by two months due to ignoring the detailed matching between logistics bills of lading and contracts,which affected the raw material procurement plan.

3.How Zhongshen Helps Enterprises Implement the Tax Refund Policy

Zhongshen has been engaged in foreign trade agency services for over 20 years,and provides precise services for Shanghai enterprises in response to the 2026 new tax refund rules:

• Accurate Commodity Code Classification: Relying on a 20-member professional customs declaration team,combined with the 2026 latest revised HS code version,we sort out the accurate codes for enterprises’ exported goods.In the past six months,we have helped 120 enterprises avoid tax refund risks caused by incorrect codes.
• Full-Link Document Optimization: Assist enterprises in organizing materials such as purchase contracts,logistics bills of lading,and foreign exchange receipts to ensure consistency with the requirements of tax authorities,and increase the audit pass rate of tax refund materials to 98% on average.
• Trade Mode Adaptation Services: For special scenarios such as cross-border e-commerce and processing trade,we help enterprises judge whether they meet the tax refund eligibility criteria.For example,under Model 1039,eligible commodities with a single invoice amount of 5,000 yuan or more can enjoy the policy through the "market procurement tax refund channel".Zhongshen has helped 30 enterprises complete the application for this channel,with a cumulative tax refund of over 2 million yuan.

Comparison of Common Shanghai Export Tax Refund Scenarios in 2026

4.Practical Suggestions for Enterprises: Conduct "Tax Refund Pre-Judgment" Before Exporting

Mr.Lu from Zhongshen suggested that Shanghai foreign trade enterprises can predict the feasibility of tax refunds in three steps before signing export contracts: 1.Confirm the commodity HS code (available through Zhongshen’s free code query service); 2.Check whether the trade mode is within the tax refund scope; 3.Organize a full-link document list to avoid missing materials later.If enterprises are unfamiliar with the policies,they can entrust Zhongshen to conduct tax refund compliance audits to reduce losses caused by policy misjudgments.In the past six months,Zhongshen has helped 50 enterprises avoid tax refund application rejections and recovered losses of over 800,000 yuan.