Direct answer: Use 9610 for direct-to-consumer cross-border B2C parcels declared one-by-one or batch-aggregated; use 9710 for B2C exports that do not fit 9610, typically retail online orders shipped via traditional general trade channels; use 9810 when goods are exported in bulk to an overseas warehouse (commonly an Amazon FBA or third-party fulfillment center) and then sold to overseas consumers. All three are eligible for VAT export refund, but each has distinct declaration, evidence and reconciliation requirements. Mixing codes on the same shipment is a typical audit trigger.
1. Why three codes exist for cross-border e-commerce exports
Before 2014, Chinese cross-border e-commerce exports had no dedicated customs regime and were forced through general trade (0110) declarations, which are document-heavy and slow for parcel-scale businesses. The State Council and General Administration of Customs introduced three purpose-built codes to match the realities of online retail exports:
- 9610 — "B2C direct purchase export," for parcel-by-parcel or aggregated cross-border retail shipments.
- 9710 — "B2C retail export, other," for cross-border retail exports that do not fit 9610, typically through general trade channels.
- 9810 — "Export to overseas warehouse," for goods exported in bulk and stored abroad before being sold to consumers.
The codes determine how customs values the goods, how the exporter submits the manifest, what logistics evidence is required and what VAT refund rate is available.
2. 9610 — parcel-by-parcel cross-border B2C
9610 is the original cross-border e-commerce export code. It applies when a Chinese seller receives individual online orders from overseas consumers and ships each parcel out, or batches multiple parcels into one customs declaration with itemized manifest.
Practical characteristics:
- Each parcel has a single customs declaration line; values must fall within the per-order thresholds set by the destination country.
- Logistics provider must be on the customs-registered cross-border B2C list and submit electronic manifest data.
- VAT refund is available at the statutory rate of the exported goods (commonly 13% or 9%); the refund is claimed on the regular VAT return by attaching the customs export declaration list.
- Best for sellers using direct cross-border logistics (Yanwen, Cainiao, SF International, YunExpress) on platforms like Amazon, eBay, Shopee, Lazada, TikTok Shop (cross-border seller model).
Common audit risk: order value exceeding the destination country's de minimis threshold, leading to seizure abroad and an unsupported refund claim in China.
3. 9710 — B2C retail export, other
9710 was added in 2020 to cover cross-border retail exports that do not fit 9610 — typically when the seller still handles the goods through traditional freight forwarders or consolidated bulk shipments but the end buyers are retail consumers abroad.
Practical characteristics:
- Declaration is closer to general trade in form, but the seller does not need a foreign importer of record on the buyer's side.
- Refund of VAT and consumption tax is available.
- Logistics evidence required is less granular than 9610 (no per-parcel manifest), but the exporter must still show end-market destination.
- Used by sellers that have shifted away from 9610 parcel-by-parcel logistics toward consolidated air or sea freight, often for mid-ticket consumer goods.
Common audit risk: customs classifies the shipment as 0110 (general trade) because the documentation is too vague about the B2C end-buyer. Once reclassified, the seller must produce an import-of-record or evidence of foreign VAT registration that is often not available.
4. 9810 — export to overseas warehouse
9810 is the most operationally relevant code for foreign sellers using overseas fulfillment centers — Amazon FBA being the canonical example. Goods are exported in bulk from China to an overseas warehouse, stored for up to a year (or longer under pandemic-era extensions), and then sold to overseas consumers from that warehouse.
Practical characteristics:
- Requires the seller to register the overseas warehouse with Chinese customs and maintain a clear inventory ledger that ties bulk exports to subsequent consumer sales.
- VAT export refund is available at the standard rate of the goods. Refund timing depends on whether the seller uses the "refund first, reconcile later" pilot program (退税前置) or the traditional approach (refund after overseas sales reconciliation).
- If goods are transferred between overseas warehouses or returned from the overseas warehouse back to China, the exporter must file the corresponding inbound/outbound declarations within customs-set deadlines.
- Best for Amazon FBA sellers, eBay store owners with US/EU warehouses, Shopify merchants using 3PLs, and TikTok Shop cross-border sellers using TikTok's "Fulfilled by TikTok" warehouses.
Common audit risk: goods exported under 9810 but never sold to end consumers, sitting in the overseas warehouse past the allowed storage window. Customs can demand refund reversal plus penalties. Maintaining monthly inventory reconciliation between the overseas warehouse report and the Chinese export declaration is the single most important control.
5. Tax treatment side-by-side
| Item | 9610 | 9710 | 9810 |
|---|---|---|---|
| Typical model | Direct-to-consumer parcel | Consolidated B2C retail shipment | Bulk export to overseas warehouse |
| Declaration granularity | Per-parcel manifest aggregated | Bulk declaration with B2C evidence | Bulk declaration, overseas warehouse-registered |
| VAT export refund | Yes, at statutory rate of goods | Yes, at statutory rate of goods | Yes, at statutory rate of goods; pilot allows faster refund |
| Income tax | Cross-border e-commerce retail export CIT exemption available | Same exemption available with required filings | CIT exemption available but overseas warehouse return/recovery needs careful tracking |
| Inventory reconciliation | Not applicable per-parcel | Reconcile bulk-out to retail sales evidence | Mandatory monthly reconciliation |
| Main audit risk | Parcel exceeds destination de minimis | Mis-classified as 0110 general trade | Unsold goods past storage window |
Note: The cross-border e-commerce retail export CIT exemption applies only if the seller is registered as a cross-border e-commerce enterprise with customs and the export value stays within the prescribed cap (RMB 5 million per enterprise per year under the current rules). Larger sellers should weigh this against regular CIT credits.
6. Operational pitfalls when codes are mixed
Many foreign-owned e-commerce businesses use more than one channel: 9810 for the bulk-shipped Amazon FBA inventory, 9610 for direct-to-consumer orders on Shopee, 9710 for some European routes. The risk is twofold:
- Wrong code on a shipment — picked because of freight convenience rather than regulatory fit. Customs can reclassify and demand a back-tax payment plus a fine, often 1–5x the underpaid amount.
- Mixing channels without separate inventory ledgers — the same physical goods being tracked under two codes, leading to either duplicate refund claims or unreconciled overseas inventory.
A practical internal control: maintain one warehouse sub-ledger per export code, with customs declaration numbers as the primary key, and reconcile monthly with the overseas warehouse report and the platform settlement.
7. Where Caigeek fits
Caigeek supports foreign-owned cross-border e-commerce sellers in China with monthly bookkeeping that ties VAT export refunds, CIT exemption claims and overseas warehouse inventory into a single set of books. We coordinate with licensed customs brokers on the declaration process and with tax agents on the refund filings. Engagement starts with mapping the export channels (9610/9710/9810/0110 mix), the overseas warehouse footprint and the platform mix.
Frequently asked questions
1. Which code applies to Amazon FBA shipments from China?
9810. Goods shipped in bulk to an Amazon fulfillment center and held there for later sale fall under the overseas-warehouse export code, regardless of whether Amazon is the platform or a separate marketplace is used.
2. Can I use both 9610 and 9810 in the same company?
Yes, many sellers do. The two codes must be tracked in separate inventory sub-ledgers, with distinct customs declaration numbers and separate VAT refund filings. Mixing them in the same VAT return is an audit trigger.
3. How long can 9810 goods stay in the overseas warehouse?
Under standard rules the storage window is 12 months, with extension possible under pilot programs. Goods unsold past the window are treated as having left the export channel; VAT refund is reversed and CIT exemption may be withdrawn.
4. Is the cross-border CIT exemption automatic?
No. The seller must be registered as a cross-border e-commerce enterprise with customs and the export value must stay within the annual cap. The CIT exemption is forfeited if conditions are not met, and the regular 25% (or 20% for small low-profit) rate applies.
5. What happens if customs reclassifies my 9710 as 0110 general trade?
Customs will require an importer of record on the foreign side, plus additional commercial invoice and freight documentation. If the seller cannot produce them, the export declaration may be voided and the VAT refund reclaimed, with a penalty of up to five times the underpaid VAT.
6. Do I need a separate license to use 9810?
You need to register the overseas warehouse with Chinese customs and provide the warehouse operator's contact, address and storage capacity. The export entity itself does not need a separate license beyond its existing customs registration.
Important notes
This article provides general information about Chinese customs codes for cross-border e-commerce exports. It is not tax, customs, legal or accounting advice for any specific company. Customs code assignment, refund eligibility thresholds and the CIT exemption cap change; confirm the latest position with the local customs office, a licensed customs broker and a qualified tax agent.