Official Policy Update
A common pitfall for many enterprises:
Goods are declared to customs well in advance, but the tax rebate declaration is only filed much later; or customs declaration is made early, but the goods leave the country late.
Export Date ≠ Declaration Date. The policy criteria only recognize the Export Date!
I. What Exactly Are These Two Dates?
1 Export Date (The core factor for determining the tax rebate rate)
- •Customs declaration for export of goods (excluding bonded zones): Based on the export date indicated on the customs declaration form. This date is usually the date when the means of transport completes the exit procedures and the goods actually leave the country. This date is used to match the applicable tax rebate rate.
- •Bonded zones/Exports through bonded zones: Based on the departure date on the Outbound Goods Filing List.
- •Non-customs declaration exports: Based on the date the export invoice is issued.
2 Declaration Date is Divided into Two Types; Do Not Confuse Them:
- •Customs Declaration Date: The time when the enterprise submits customs declaration materials to customs (often earlier than the actual departure).
- •Tax Rebate Declaration Date: The time when the finance department submits tax rebate materials via the electronic tax bureau (can be declared months after export).
Policy original text:
The applicable tax rebate rate for products adjusted this time is defined by the export date indicated on the export goods customs declaration form. Even if you only file for the tax rebate after April 1, 2027, as long as the export date on the customs declaration form is before April 1, 2027, the old tax rebate rate still applies; conversely, if the goods’ export date is on or after April 1, 2027, the new tax rebate rate is directly implemented.
Example:
① Export date on the customs declaration form: March 28, 2027; tax rebate declared in May 2027. [Result] The export date is before the policy takes effect, so new energy vehicles are still rebated at 13%.
② Export date on the customs declaration form: April 5, 2027; tax rebate declared on April 10, 2027. [Result] The export date falls within the new policy period, so new energy vehicles can only be rebated at 9%.
II. What Should Enterprises Do Now to Reduce Losses?
- Check undelivered orders on hand to distinguish whether they involve products on the new energy vehicle or electronic cigarette device lists.
- Check commodity HS codes against the announcement’s appendix list to confirm whether they fall within the adjustment scope.
For products on the list:
- Before April 1, 2027: Ensure the export date on the customs declaration form falls before the deadline.
- After April 1, 2027: Factor reduction into external quotations and contract pricing.
- Track manifest and customs clearance progress, verify electronic port data.
- Lock in input invoices and maintain tax exemption/credit ledgers.
- Distinguish between bonded zone and non-customs declaration rules.
- Conduct pre-declaration for tax rebates to verify commodity codes.
Export goods must complete foreign exchange receipts before April 30 of the year following the customs export date. In special circumstances where foreign exchange cannot be received, prepare evidence materials for deemed foreign exchange receipts in advance.
III. Quick Overview of Common Questions
The effective node of the tax rebate rate adjustment depends on the export date indicated on the customs declaration form; the tax rebate declaration date does not determine the tax rate. Foreign trade enterprises should not just focus on the declaration time, but must manage shipping schedules, departure times, and order quotations in advance. Review your orders on hand now, calculate profits in advance, adjust quotation plans, and protect your enterprise’s export profits!
Forward this to your company’s business, procurement, and finance colleagues to avoid tax rebate losses in advance!
Post time: Oct-19-2026