With the global tax regulation entering a new stage of "transparency+strong enforcement", the implementation of OECD digital tax rules, the deepening of CRS information exchange, and the precise supervision of cross-border data by the domestic Golden Tax Phase IV system, cross-border sellers are facing increasing compliance pressure. Recently, tax departments in multiple regions have conducted special inspections on cross-border e-commerce, focusing on core points such as consistency between export data and declaration, and authenticity of tax refund vouchers; Amazon, Wal Mart and other cross-border platforms also synchronously upgrade compliance requirements, and add new functions such as tax registration verification, real-time synchronization of sales data. Non compliant sellers will face the risk of account flow restriction, capital freeze, or even being cleared. Compliance has become a mandatory course for the survival and development of cross-border e-commerce. This article combines the latest policy developments in 2025, summarizes the characteristics and adaptation scenarios of mainstream customs declaration models, provides customized compliance solutions for sellers of different sizes, and answers high-frequency tax questions to help sellers accurately avoid pitfalls and grasp policy dividends.

Mainstream cross-border e-commerce export customs declaration mode by 2025

(Policy Update Version)

1、 9610 mode: Small cross-border direct mail (policy continuation+efficiency upgrade) 

🔹  Applicable sellers: Small and medium-sized sellers on platforms such as AliExpress, TikTok Shop, Shopee, and independent self shipping merchants, specializing in light and small items such as 3C accessories, clothing, and beauty products.   

🔹  Core features: Optimization of the "list release and summary declaration" mechanism, achieving automatic data integration between customs and tax systems by 2025, and shortening the tax refund declaration cycle to 7 working days; Support fast customs clearance for orders with a single ticket amount of less than 5000 yuan.   

🔹  Restrictions and precautions: If the value of a single shipment exceeds 5000 yuan, it must be converted to a general trade declaration; Tax refund does not require additional electronic information on the payment receipt. Complete logistics tracking, order screenshots, and other supporting materials must be provided. Inconsistent data will affect the tax refund review. Cross border e-commerce retail exports and cross customs returns are supported, and returned goods must be returned to designated customs supervision workplaces. 

2、 9710 mode: B2B direct export of cross-border e-commerce (strengthened supervision)

🔹  Applicable sellers: B2B platform merchants such as Alibaba International and Made in China, traditional foreign trade transformation enterprises, and direct export of bulk goods to overseas enterprises.   

🔹  Core features: Essentially, it is "online general trade", with the addition of "electronic contract filing" requirements in 2025, which require signing electronic contracts through a platform recognized by customs and uploading them for filing; Enjoy the same tax refund policy as general trade, support integrated national customs clearance, and have the flexibility to choose the shipping port.   

🔹  Risk Warning: Order, logistics, and fund data must be completely matched. False transactions and data tampering will face administrative penalties from customs, affecting the credit rating of the enterprise. 

3、 9810 mode: Cross border e-commerce export overseas warehouse (tax rebate new policy dividends) 

🔹  Applicable sellers: Amazon FBA sellers, self built overseas warehouse enterprises, specializing in high sales and high turnover SKUs of home furnishings, electronic products, outdoor products, etc.  

🔹  Core feature: By 2025, the "tax refund upon departure" policy will be fully implemented. After the goods arrive at overseas warehouses and complete customs clearance, tax refunds can be applied for without waiting for terminal sales; Support the "bulk stocking+overseas distribution" mode, greatly improving the delivery time.   

🔹  Challenge and Response: There is significant upfront funding pressure, which can be alleviated through the use of supply chain financial tools to ease the pressure on capital turnover; No need to handle overseas warehouse business registration, electronic data of warehouse booking form needs to be transmitted to customs, and inventory data needs to be submitted regularly. 

4、 1210 mode: Bonded e-commerce mode (increased entry threshold)

🔹  Applicable sellers: Medium to large enterprises with strong financial strength, operating under the "bonded stocking" model, such as Tmall Global and JD Global's resident merchants.   

🔹  Core features: Goods can apply for tax refunds by entering the comprehensive bonded zone in batches, and consumers can directly ship from the bonded zone after placing orders, with a time efficiency comparable to domestic e-commerce; In 2025, there will be a requirement for real-time supervision of inventory in bonded zones, and inventory data must be synchronized with the customs system.   

🔹  Admission requirements: Applicants must obtain the qualification to enter the bonded zone and have a registered capital of no less than 5 million yuan; Batch stocking requires high capital turnover ability and is suitable for brand sellers with high SKU concentration. 

5、 0110 Mode: Traditional General Trade (Policy Stability+Tax Refund Optimization)

🔹  Applicable sellers: Traditional foreign trade transformation enterprises that export large quantities, high-value, branded products (such as machinery and equipment, high-end electronic products).   

🔹  Core features: The policy is the most stable, with the highest tax refund rate (10% -13%). By 2025, the efficiency of tax refund review will be improved, and the average time for tax refund to be received will be compressed to 15 working days; Strong universality, suitable for various export scenarios.   

🔹  Key requirements: Complete contracts, invoices, packing lists, and other documents must be provided, and all information must be strictly consistent with the customs declaration; Input invoices must be genuine and valid, and false invoices must be strictly prohibited. 

6、 1039 mode: Market procurement trade (quota increase+scope expansion) 

🔹  Applicable sellers: Small and medium-sized merchants who do not have import and export rights, have scattered procurement channels, and find it difficult to obtain input invoices, such as merchants in Yiwu Small Commodity City and Guangzhou Foreign Trade City, are required to complete registration on the market procurement and trade networking information platform.   

🔹  Core feature: The upper limit of single shipment value will be raised from 150000 US dollars to 200000 US dollars by 2025; Exemption from value-added tax, no need to issue value-added tax invoices, and enjoy the approved collection policy of 0.4% -1%; Add the function of "online procurement filing" to simplify the filing process.   

🔹  Core advantage: Specializing in solving the problem of "no ticket export" for small and medium-sized merchants, with the lowest compliance cost and convenient procedures. 

7、 New: 9610B model (B2B direct mail for cross-border e-commerce, pilot promotion in 2025) 

🔹  Applicable sellers: Sellers who export goods to overseas small batch purchasers through independent websites or small B platforms, with order amounts ranging from 5000 yuan to 500000 yuan.   

🔹  Core features: Combining the convenient customs clearance of 9610 with the B2B attributes of 9710, supporting "list declaration+summary tax refund"; No need to provide a complete foreign trade contract, only order screenshots and logistics vouchers are required.   

🔹  Pilot scope: By 2025, it will be piloted in cross-border e-commerce pilot zones such as Guangdong, Zhejiang, and Jiangsu, and gradually promoted nationwide.

Customized compliance solutions for different types of sellers

(2025 optimized version)

• Start up seller (annual sales below 1 million yuan) 

🔹  Core demand: Minimize compliance costs, start quickly, and avoid initial tax risks.   

🔹  Recommended solution: 1039 market procurement trade (preferred for export without tickets)+9610 small direct mail (supplementary for small batch orders).   

🔹  Implementation points: Relying on market procurement and trade clusters (such as Yiwu and Guangzhou) to complete filing, there is no need to handle import and export rights on one's own; Choose compliant market procurement and trade agents to ensure complete document filing; Avoid excessive declaration (single ticket ≤ 200000 US dollars), otherwise it needs to be converted to general trade.       

• Small and medium-sized sellers (annual sales of 1-5 million yuan) 

🔹  Core demand: Balance compliance costs and tax refund benefits, simplify operational processes, and support business expansion.   

🔹  Recommended solution: 1039 market procurement trade (main mode)+9610B mode (small B order supplement).   

🔹  Advantages: Non ticket orders can be exported in compliance with the 1039 mode to reduce tax burden, while small B orders can enjoy convenient customs clearance and tax refund through the 9610B mode to increase profits, without the need to invest a large amount of capital to build a compliance system, suitable for rapid expansion stages.       

• Medium to large sellers (with annual sales of over 5 million yuan) 

🔹  Core demand: Maximize tax refund revenue, ensure brand compliance, and adapt to multi platform and multi warehouse operations.   

🔹  Recommended solution: 0110 general trade (branded products, high-value products)+9810 overseas warehouse model (large-scale products).   

🔹  Implementation points: Apply for general taxpayer qualifications, standardize input invoice management, and ensure smooth tax refunds; Overseas warehouses need to complete customs filing, regularly submit inventory and sales data, and enjoy the "tax refund upon departure" policy; Establish a four in one management system of "order logistics funds invoice" to cope with tax verification.      

• Multi platform+multi category sellers (annual sales of over 10 million yuan) 

🔹  Core demand: Isolate business line risks, achieve refined compliance management, and optimize overall tax burden. Recommended solution: "Mode splitting+independent accounting+data isolation" system.   

🔹  Practical example: Brand flagship stores, high-value products (such as 3C digital and high-end beauty products): go through 0110 general trade to maximize tax refunds;   

🔹  White label distribution and low value products (such as household daily necessities and accessories): Purchase and trade through the 1039 market to reduce tax burden;   

🔹  Overseas warehouse stocking products: adopt the 9810 mode and enjoy the new tax refund policy; Small B wholesale orders: adopt the 9610B mode to improve customs clearance efficiency; Risk isolation: Separate accounting accounts are established for different business lines, and logistics documents and declaration data are strictly distinguished to avoid single business violations affecting overall operations.      

• Cross border brand seller (global layout) 

🔹  Core demand: Global tax compliance, avoidance of double taxation, and maintenance of brand image.   

🔹  Recommended solution: 0110 general trade (core market)+9810 overseas warehouse (localized operation)+cross-border tax planning (reasonable tax avoidance).   

🔹  Advanced strategy: Establish regional operation centers in Hong Kong or Singapore to coordinate global capital flow; Utilize bilateral tax treaties to apply for tax credits and avoid double taxation; Standardize overseas warehouse tax declaration, such as EU VAT, US sales tax, etc., to avoid local tax penalties.

Answers to high-frequency tax compliance issues in 2025

1、 Will there be any changes in the criteria for identifying small-scale taxpayers and general taxpayers in 2025?

🔷  No change: Small scale taxpayers with annual sales below 5 million yuan; Annual sales exceeding 5 million yuan will be forcibly recognized as a general taxpayer.          

🔷  Additional explanation: Small scale taxpayers can voluntarily apply to become general taxpayers, suitable for sellers with tax refund needs and rapidly expanding business scale.  

2、 Is there any other compliance path besides 1039 mode without input invoice? There are two supplementary options: 

🔷  Select the 9610B mode (small B order), no input invoice is required, only the order and logistics voucher need to be provided;          

🔷  Entrust qualified foreign trade comprehensive service enterprises (such as Sinotrans and Huamao Logistics) to act as agents for exports, providing "no invoice customs declaration+compliance declaration" services, but paying a certain service fee.  

3、 Do I need to declare and pay taxes for the inventory backlog in overseas warehouses?          

🔷  Domestic taxation: The export declaration has been completed when the goods leave the country, and there is no need to pay duplicate taxes domestically due to inventory backlog;          

🔷  Overseas taxation: It is necessary to comply with local tax regulations. If the inventory in EU countries exceeds a certain period, storage tax may be required. Some states in the United States levy property tax on long-term backlog inventory, and local policies need to be understood in advance.  

4、 What are the key changes in the export tax rebate policy in 2025?          

🔷  Tax refund efficiency improvement: The time for general trade tax refunds to be received has been shortened to 15 working days, and the time for 9810/1210 mode tax refunds to be received has been shortened to 7-10 working days;          

🔷  Strengthen tax refund verification: Focus on verifying the authenticity of input invoices and the completeness of logistics trajectories. False tax refunds will face fines and tax recovery;          

🔷  New "Fault Tolerance Mechanism": Declaration errors caused by system failures or data transmission delays can be corrected within 30 days without penalty.  

5、 Is it still possible to operate the bill for export now? What are the risks?          

🔷  Not recommended operation: By 2025, the customs and tax system data will be integrated, and the goods that are paid for export cannot complete compliance declaration, resulting in a disconnect between capital flow and cargo flow, which is easily identified as "false export" 

🔷  Risk consequences: Faced with tax recovery, fines, corporate credit downgrade, related accounts may be frozen, and those with serious circumstances will be included in the "List of Dishonest Enterprises", restricting cross-border business operations.

Conclusion: Compliance is the long-term moat of cross-border e-commerce

In 2025, global cross-border tax compliance will enter a "deep water zone", and regulation will no longer be "loud thunder, small raindrops", but "precise and normalized". For sellers, compliance is no longer an additional cost, but a core competitiveness to avoid risks and enjoy policy dividends - standardized declaration processes can help you smoothly obtain tax refunds, compliance mode selection can help you avoid account freezing, and comprehensive tax planning can optimize your overall tax burden.

It is recommended that sellers choose a suitable customs declaration mode and compliance plan based on their own business scale, product type, and platform layout, and establish a full process compliance system of "pre planning, in-process control, and post review". In the era of tax transparency, only by holding the bottom line of compliance can we achieve stable and sustainable development in the global market.