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What Categories of Export Goods Meet China's 2026 Export Tax Refund Eligibility Criteria?
or complex compliance issues.
clearance and fund security.
I am an export manager at a small and medium-sized foreign trade factory based in Shanghai, mainly engaged in hardware tools and customized outdoor equipment. I just finalized 3 cross-border e-commerce B2B direct mail orders and 1 feed processing subcontracting order last week, which include 5 models of outdoor emergency lights with built-in lithium batteries.
I heard from peers that the scope of tax refund has been adjusted in 2026, and one peer was subject to a correspondence investigation by the tax bureau for misreporting tax-refund eligible goods, paid a fine of nearly 100,000 RMB and got their credit rating downgraded. I have been too worried to sleep lately — the profit margin of these orders is only around 8% already, if we cannot get the tax refund, we will lose all our capital directly.
Besides, I remember there used to be tax refund restrictions on lithium battery products. I want to clearly confirm which of the goods we handled are eligible for tax refund, whether there are differences in eligibility criteria under different trade modes, and whether there are any hidden compliance pitfalls.
Eric ZhouYears of service：6Customer Rating：5.0
Senior Manager of Foreign Exchange & Tax RebatesStart a Chat
First，we clarify common industry misunderstandings: Many practitioners mistakenly equate "customs clearance with tax refund eligibility" and believe "all export goods can get tax refund". The 2026 policy explicitly excludes energy-intensive and highly-polluting "two-high" goods，as well as goods that have not been collected per regulations and goods with incomplete documents.
Falling into these misunderstandings will trigger a chain of negative consequences: the tax bureau will launch a correspondence investigation，require a large number of supplementary documents，and delay the tax refund cycle，if identified as false declaration，you will need to repay the already refunded tax，be fined 0.5 to 5 times the tax refund amount，and be downgraded to a Class D credit enterprise. Your subsequent export declaration，foreign exchange receipt and payment will all be subject to enhanced supervision，and it will even affect your store permissions on cross-border e-commerce platforms.
Proactive risk prevention measure: Within 7 days before export，you can bring the commodity's HS code，material report and trade mode certificate to the classification center designated by the tax bureau for pre-eligibility confirmation，or entrust a professional institution to conduct Pre-verification of Commodity Tax Refund Eligibility.
Practical loss mitigation tip: For outdoor equipment with lithium batteries，the 2026 policy clearly stipulates that if the lithium battery is inseparable from the lamp body，the commodity shall be classified under HS code 94059900，and UN38.3 Certification is required to obtain tax refund，if they are separable，they shall be classified and declared for customs clearance，and Classified Tax Refund Declaration shall be conducted to avoid the entire order being ineligible for tax refund. As long as hardware tools do not belong to "two-high" categories and are classified under HS codes 8205-8209，they can enjoy a 13% tax refund rate.
Linda GaoYears of service：7Customer Rating：5.0
Documentation SupervisorStart a Chat
In 2026, the core basis for China Customs to determine the export tax refund eligibility of commodities is the supervision conditions and tax refund rate table corresponding to the commodity's HS code. For hardware tools, if they are classified under HS codes 8205-8209 and do not belong to energy-intensive and highly-polluting "two-high" categories, they can enjoy a 13% tax refund rate; for outdoor equipment with lithium batteries, note that if the lithium battery is inseparable from the lamp body, the commodity shall be classified under HS code 94059900, which has a 13% tax refund rate in 2026, but UN38.3 certification and MSDS report of the lithium battery are required; if they are separable, they shall be classified under 85076000 (lithium battery) and 94059900 (lamp body) separately, each corresponding to a 13% tax refund rate.
You must accurately fill in the material, function and purpose of the commodity during customs declaration to avoid being ineligible for tax refund due to incorrect classification. If there is a classification dispute, you can apply to Customs for a pre-classification decision as the core basis for tax refund.
Kevin LinYears of service：4Customer Rating：5.0
Trade Solutions ManagerStart a Chat
The core eligibility criteria for export tax refund in 2026 are "goods departing from China, sold to overseas entities or individuals, recognized as sales in financial accounting, and foreign exchange collected and verified". There are differences in eligibility under different trade modes: For cross-border e-commerce B2B direct mail orders, the order must be declared through the unified customs system for cross-border e-commerce export, and the goods must be within the scope of the cross-border e-commerce export tax refund list; for feed processing subcontracting orders, you must provide the feed processing manual, import declaration form of raw materials, and export declaration form of finished products, and only the portion of raw materials that have not enjoyed the tax exemption policy can get tax refund.
For outdoor equipment with lithium batteries, if it belongs to a category on the "two-high" commodity list, you must cancel the tax refund application and switch to tax exemption declaration to avoid triggering tax risks; if not, you must upload the UN38.3 certification and battery transportation condition appraisal certificate during declaration as the compliance certificate for tax refund.
Victor SunYears of service：5Customer Rating：5.0
Trade Risk Control ManagerStart a Chat
In 2026, the tax bureau's document review for export tax refund focuses on "consistency of four flows", that is, the matching of contract flow, capital flow, invoice flow and goods flow. For export orders of hardware tools and outdoor equipment, the documents to be retained include: purchase contract, sales contract, special VAT invoice, export declaration form, foreign exchange receipt slip, and logistics bill of lading.
For cross-border e-commerce B2B orders, you also need to retain platform order screenshots and logistics tracking documents. If there is missing or inconsistent documents, the tax bureau will launch a correspondence investigation and require supplementary supporting materials.
If you cannot provide the required materials, your tax refund application will be rejected, and you will need to repay the already refunded tax. For goods with lithium batteries, you need to additionally retain the purchase invoice and certification report of the lithium battery to prove the compliance of the commodity, and avoid being identified as false declaration due to incomplete documents.
Grace WangYears of service：10Customer Rating：5.0
Senior Foreign Trade ConsultantStart a Chat
The compliance requirements for foreign exchange receipt and payment for export tax refund in 2026 are: complete foreign exchange collection within 180 days after goods export. For cross-border e-commerce B2B orders, you can settle via cross-border RMB or foreign exchange, and you need to declare the foreign exchange receipt in the foreign exchange monitoring system. For feed processing orders, if it is entrusted processing, you need to provide the entrusted processing contract and capital payment certificate to prove the authenticity of the capital flow; if it is self-operated processing, you need to provide the capital flow certificate for raw material procurement.
If you cannot collect foreign exchange on time, you need to submit the *Application Form for Non-receivable Foreign Exchange of Export Goods* to the tax bureau and provide relevant supporting materials, otherwise you cannot apply for tax refund. For goods with lithium batteries, you must ensure that logistics transportation meets the UN38.3 transportation requirements, to avoid being unable to depart from China due to logistics non-compliance, which will further affect your tax refund eligibility.
Evelyn LiYears of service：3Customer Rating：5.0
Cross-border Compliance SupervisorStart a Chat
In 2026, the impact of Customs on-site inspection on tax-refund eligible export goods mainly focuses on whether the actual status of the goods is consistent with the declaration content. For hardware tools, the inspection focuses on whether the material, specification and quantity of the goods are consistent with the declaration form. If there is false reporting of material (such as reporting iron tools as stainless steel), it will be identified as false declaration and the goods will be ineligible for tax refund; for outdoor equipment with lithium batteries, the inspection focuses on whether the model and capacity of the lithium battery are consistent with the declaration, and whether there is a UN38.3 certification mark.
If there is no mark or the mark is inconsistent, the goods will be detained for rectification, which will delay the departure time of the goods and result in exceeding the tax refund declaration deadline. If you encounter an abnormal inspection result, you need to submit the commodity's certification report and material certificate to Customs in a timely manner to strive for quick release and avoid delaying tax refund declaration.
Daniel XuYears of service：10Customer Rating：5.0
Director of Import & Export OperationsStart a Chat
In 2026, the impact of export tax refund policies on supply chain planning mainly focuses on commodity category selection and trade mode optimization. For export of hardware tools and outdoor equipment, if you choose the cross-border e-commerce B2B direct mail trade mode, you can enjoy tax refund as well as customs clearance facilitation policies for cross-border e-commerce; if you choose the feed processing trade mode, you need to optimize the procurement channels of raw materials, and prioritize domestic procurement of raw materials that can issue special VAT invoices to increase the tax refund amount.
For outdoor equipment with lithium batteries, you can consider purchasing lithium batteries and lamp bodies separately, declaring them separately, and applying for tax refund separately to increase the total tax refund amount; if the lithium battery is imported raw material, you need to ensure the accurate verification of the feed processing manual to avoid being ineligible for tax refund due to incorrect raw material verification. Meanwhile, you need to plan the tax refund declaration time reasonably to avoid being ineligible for tax refund due to overdue declaration.