What Taxes Are Eligible for Export Tax Refund? Full Analysis of 2026 Latest Policy

What Taxes Are Eligible for Export Tax Refund?Full Analysis of 2026 Latest Policy

Since 2026,the volume of export tax refund declarations by Shanghai foreign trade enterprises has increased by 12% year-on-year,but many leaders of small and medium-sized foreign trade enterprises like Mr.Gu still have doubts about what taxes are actually refundable for export tax refund.As Zhongshen with over 20 years of deep experience in the industry,more than 60% of the policy inquiries received recently focus on two core issues: "tax refund rate adjustment" and "document compliance".This article combines the latest 2026 foreign trade policy to break down the core tax types and implementation logic of export tax refund.

1.Policy Breakdown: 3 Key Changes of 2026 Export Tax Refund

In March 2026,the State Taxation Administration of China jointly issued the *Notice on Optimizing Export Tax Refund Policy* with the General Administration of Customs,and core adjustments are concentrated in the following three points:

• Linked Adjustment of Tax Refund Rate and Value-Added Tax Rate: The export tax refund rates for 12 categories of goods including mechanical equipment and new energy components in the manufacturing industry have been uniformly increased from the original 13%/10% to 15%,achieving "consistent taxation and refund" with the domestic value-added tax rate (15%); the tax refund rates for high-energy-consumption and high-pollution goods have been lowered by 2-3 percentage points,and tax refund for some goods is canceled.
• Expansion of Tax Refund Scope in Shanghai Pilot Free Trade Zone: Goods under the "9610" and "1210" supervision modes for cross-border e-commerce retail exports (B2C) in the zone have been included in the export tax refund scope for the first time,covering 18 categories of daily consumer goods such as clothing and 3C electronics.
• Paperless Declaration Covers the Whole Process: All export enterprises can directly submit electronic documents such as customs declaration forms and value-added tax special invoices through the electronic port,and the electronic tax refund time limit of the tax authority has been shortened from the original 5 working days to within 3 working days.

It needs to be clarified that export tax refund is not "refunding all taxes".The core refund is the value-added tax and consumption tax already paid in the domestic production and circulation links of exported goods — this is the basic logic of the policy.The 2026 adjustment only targets the tax refund rate,scope and process,and does not change the nature of the tax types.

2.Impact on Enterprises: Coexistence of Opportunities and Challenges

For the actual operation of Shanghai foreign trade enterprises,the impact of the 2026 export tax refund policy can be divided into two dimensions:

(1) Opportunities: Faster Capital Withdrawal,Expanded Profit Margin

Take a new energy component enterprise served by Zhongshen as an example.In 2026,its export volume increased by 20% year-on-year.After the tax refund rate increased from 13% to 15%,the monthly tax refund amount increased by about 80,000 RMB,and an extra 960,000 RMB of capital can be withdrawn throughout the year.In addition,after the implementation of the cross-border e-commerce tax refund policy in the Pilot Free Trade Zone,a clothing e-commerce enterprise can get an additional tax refund of about 30,000 RMB per month,which solves the pain point of "slow capital turnover" for small and medium-sized e-commerce enterprises.

Supervisor Lyu (Head of Tax Refund Department of Zhongshen) said: "After the implementation of paperless declaration in 2026,the average time for tax refund to arrive for enterprises we assist has been shortened by 2 days,and some enterprises in the Pilot Free Trade Zone can get the refund in as fast as 1 working day,which is crucial for small and medium-sized foreign trade enterprises with tight cash flow."

(2) Challenges: Higher Compliance Requirements,Increased Difficulty in Policy Understanding

Policy adjustments also bring new challenges: First,the review of document consistency is stricter.Through the Golden Tax Phase IV system,tax authorities conduct intelligent comparison of three elements: "product name,quantity,unit price" on customs declarations,value-added tax invoices,and contracts.In the first half of 2026,the delay rate of tax refund caused by inconsistent documents in Shanghai increased by 8% year-on-year; Second,the tax refund rate of some goods is lowered,and high-energy-consumption enterprises need to adjust their export product structure,otherwise their profits will drop by 5%-10%; Third,the implementation details of the new policy in the Pilot Free Trade Zone are complicated,and it is difficult for small and medium-sized e-commerce enterprises to accurately grasp the declaration process.

3.Implementation Services of Zhongshen: Help Enterprises Seize Opportunities and Avoid Risks

In response to the changes in the 2026 export tax refund policy,Zhongshen relies on more than 20 years of industry experience to provide targeted services for Shanghai foreign trade enterprises:

Policy Change Point	Service Content of Zhongshen	Benefits for Enterprises
Linked adjustment of tax refund rate	1.Sort out commodity HS codes for enterprises for free,match the latest tax refund rate; 2.Customize tax refund calculation plan,optimize cost structure	Avoid undercalculation of tax refund rate caused by coding errors,increase the total tax refund amount by 5%-8% on average
Expansion of tax refund scope in Pilot Free Trade Zone	1.Assist e-commerce enterprises to complete filing for "9610" and "1210" modes; 2.Prepare logistics and payment certificates required for tax refund on behalf of enterprises	Small and medium-sized e-commerce enterprises can quickly enjoy the tax refund policy without building their own compliance team
Paperless declaration requirements	1.Train enterprise operators on electronic port declaration procedures; 2.Submit electronic documents on behalf of enterprises and track the review progress in real time	Shorten the tax refund arrival time to within 3 working days,reduce manual errors
Tighter compliance review	1.Pre-review of the three elements of documents; 2.Regularly update policy compliance lists	Increase document consistency rate to 99%,avoid tax refund delay

Mr.Gu (head of a mechanical equipment export enterprise) feedback: "Previously,due to wrong HS codes,we undercalculated the tax refund rate for some goods by 2 percentage points,resulting in a loss of about 30,000 RMB per month.After entrusting Zhongshen,they re-sorted 120 commodity codes,and now we get nearly 40,000 RMB more in tax refund per month,which also saves the time of our finance team."

4.Practical Suggestions: Update Commodity Tax Refund Rate List Monthly

In response to the dynamic adjustment of the 2026 export tax refund policy,it is recommended that Shanghai foreign trade enterprises: update the latest tax refund rate list corresponding to commodity HS codes through the official website of the State Taxation Administration or via a professional agency before the 10th of each month.Avoid undercalculation of tax refund rate or declaration errors caused by untimely update of codes — Zhongshen can provide enterprises with free real-time tax refund rate inquiry services to ensure that enterprises can enjoy policy dividends as soon as possible.

It should be noted that export tax refund is only applicable to goods that "have been cleared,departed from the territory and sold to overseas units or individuals",and complete documents and materials are required.If an enterprise has questions about policy details or declaration procedures,it can contact a professional agency for assistance to avoid affecting the tax refund progress due to improper operation.